Justia Contracts Opinion Summaries

In this construction defect case brought by homeowners against several contractors, the Supreme Court affirmed the ruling of the district court that the limitations period against each contractor began to run upon the substantial completion of each contractor's project.The district court granted summary judgment in favor of the contractors in this case, generally agreeing that the limitations period for the homeowners' claims against the contractors began to run on the dates that each contractor substantially completed its work. The Supreme Court affirmed, holding that the district court did not err in finding that Homeowners' claims against the contractors were time barred as matter of law under Neb. Rev. Stat. 25-223 and by denying their oral motion seeking leave to amend their complaint to add a new claim. View "McCaulley v. C L Enterprises, Inc." on Justia Law

Appellants William "Billy" King, and Melanie (Frantz) King ("the Kings"), hired appellee Terra Firma Builders, LLC ("TF") to perform construction work in the backyard of their home. In December 2012, TF was removed from the project before completion due to a dispute about the work performed up to that point. In 2013, TF filed two lawsuits for breach of contract and unjust enrichment, a mechanics’ lien claim for alleged unpaid labor and materials. TF effectuated service of the mechanics’ lien on the Kings by sheriff, however a month later, TF withdrew the lien and filed a new one for the same amount of the discontinued lien; this lien was assigned a new docket number. TF did not file the required affidavit of service for this lien claim. The Kings answered the suit with their own counterclaim alleging breach of contract; they did not challenge TF’s failure to file an affidavit of service at this time. In 2015, TF sought to enforce and obtain judgment on its lien. The Kings did not file preliminary objections or otherwise raise TF’s failure to file an affidavit of service at this time. In 2017, the trial court consolidated TF’s mechanics’ lien and breach of contract actions and proceeded to a bench trial. The parties agreed that TF failed to complete the project but disputed the amount of work remaining unfinished and the quality of the work completed. The court ultimately found in favor of the Kings on all claims, including the Kings’ counterclaim, and awarded the Kings monetary damages. TF moved for a new trial, which was ultimately granted. At the conclusion of the second trial, the court again found in favor of the Kings on the merits, but did not award damages. In 2018, while the post-trial motions were pending, the Kings moved to strike the mechanics’ lien because TF’ failed to file an affidavit of service to perfect the lien. TF argued the Kings had waived their right to object to the lien when they accepted service of the complaint to enforce, never filed preliminary objections, and appeared in court to defend the action. The trial court granted the petition to strike. On appeal, a divided three-judge panel of the Superior Court reversed. The Pennsylvania Supreme Court reversed, finding the lien remained unperfected and invalid, "and the applicable statutes quite logically do not specify a time limit for objection to such a thing." View "Terra Firma Builders, LLC v. King, et al.." on Justia Law

This appeal involved two lawsuits, three parties, and one contract. In the first lawsuit, three neighboring property owners incurred varying damages due to a mudslide. The three parties sued and countersued each other for negligence and other claims related to water drainage. The parties eventually settled. The owners agreed to perform mitigation and repair work on their own properties according to their own separate plans. The agreement was memorialized in a contract (the Settlement Agreement). In the second lawsuit, two owners sued the third owner (a married couple). Plaintiffs alleged defendants breached the Settlement Agreement because their work was not in substantial compliance with their plan. But in a bench trial, the court found defendants complied with the contract by providing a copy of an engineer’s report stating their work was “‘substantially completed in accordance with the approved plans.’” The court also found no evidence of bad faith, fraud, or gross negligence. On appeal, plaintiffs contended the trial court misinterpreted the Settlement Agreement. Finding no reversible error in the trial court's interpretation of the Settlement Agreement, the Court of Appeal affirmed. View "Coral Farms, L.P. v. Mahony" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing in part the circuit court's determination that the price for certain property was $16.6 million and granting County Visions Cooperative fifteen days to exercise its right of first refusal at that price, holding that a circuit court may set an exercise price that exceeds the appraised value of the burdened property.The circuit court granted Country Visions specific performance of its right of first refusal to a property that Archer-Daniel-Midland Co. was attempting to sell. At issue was whether the circuit court correctly set the price at which Country Visions could exercise its right of first refusal. The court of appeals concluded that the circuit court did not err in how it determined the appropriate right of first refusal exercise price but remanded the case for a determination of whether the $16.6 million price included personal property. The Supreme Court affirmed, holding (1) the circuit court properly considered the unique synergies that the property provided when it set the exercise price higher than the appraised value; but (2) remand was necessary to determine whether the $16.6 million exercise price included more than what was called for in the right of first refusal contract. View "Country Visions Cooperative v. Archer-Daniels-Midland Co." on Justia Law

The Estate of Frances Elaine Warren entered into a purchase and sale agreement with Tricore Investments, LLC involving real property near Priest Lake in Bonner County, Idaho. Before closing, the Estate sold the property to other buyers: John Stockton and Todd Brinkmeyer. Tricore filed a complaint against the Estate for breach of contract and violation of the Idaho Consumer Protection Act (“ICPA”), among other things, and sought specific performance of the purchase and sale agreement. The complaint also alleged that Stockton and Brinkmeyer tortiously interfered with the purchase and sale agreement and that the Estate, Stockton, and Brinkmeyer (collectively, “Appellants”) engaged in a civil conspiracy. The case proceeded to a bench trial where the district court found: (1) the purchase and sale agreement between the Estate and Tricore constituted a valid and enforceable contract; (2) the Estate breached the contract when it sold the property to Stockton and Brinkmeyer; (3) the Estate’s actions violated the ICPA; (4) Stockton and Brinkmeyer tortiously interfered with the contract; and (5) Appellants engaged in a civil conspiracy. The district court ordered specific performance of the contract but declined to award any additional damages. The Estate and Stockton jointly appealed; Brinkmeyer appealed separately. The Estate argued the purchase and sale agreement was not a valid, enforceable contract because it violated the statute of frauds and there was no meeting of the minds. In the alternative, the Estate argued it did not breach the contract because Tricore repudiated it, and it did not violate the ICPA. Stockton and Brinkmeyer argued they did not tortiously interfere with the purchase and sale agreement. Together, Appellants argued they did not engage in a civil conspiracy. The Idaho Supreme Court affirmed the district court’s grant of summary judgment for Tricore on the Estate’s statute of frauds defense. The Court also affirmed the district court's findings that: (1) the Estate breached the Tricore PSA; (2) the Estate violated the ICPA; and (3) Stockton and Brinkmeyer tortiously interfered with the Tricore PSA. The district court's finding that Appellants engaged in a civil conspiracy was reversed. As a result, the attorney fee award was affirmed only as it applied to the Estate from fees against Stockton and Brinkmeyer. Tricore was not entitled to monetary damages on the tortious interference claim. View "Tricore Investments LLC v. Estate of Warren" on Justia Law

The Supreme Judicial Court vacated the portion of the trial court's judgment denying Plaintiff's claim under Mass. Gen. Laws ch. 93A, 11 and affirmed the remainder of the judgment, holding that the judge erred in instructing the jury under section 11.The attorney defendants in this case misappropriated propriety materials from their employer during their employment and subsequently used those materials to compete with their former employer. A jury found Defendants liable on claims for conversion, conspiracy, and breach of the duty of loyalty. The jury denied relief on the plaintiff employer's claims for unfair or deceptive trade practices, in violation of section 11. The Supreme Judicial Court vacated the judgment in part, holding that Defendants may be liable for unfair or deceptive trade practices, and the judge erred in instructing the jury that Defendants' conduct before leaving their employer was not relevant to Plaintiff's claim under section 11. View "Governo Law Firm LLC v. Bergeron" on Justia Law

In this contract dispute involving the correct interpretation of a mineral lease's "continuous drilling program" provision the Supreme Court held that the court of appeals erred in reversing partial summary judgment for the lessee on the contract-construction issue.Lessor and Lessee were the successors-in-interest to an oil-and-gas top lease covering a 30,450-acre parcel of land. At the end of the primary term, Lessee was required to reassign to Lessor all of Lessee's operating rights in each tract of the lease not then held by production unless Lessee was engaged in a "continuous drilling program." Notwithstanding Lessee's continued drilling operations, Lessor filed a suit seeking a declaration that the lease had terminated. The trial court granted partial summary judgment for Lessor, concluding that the lease had not terminated as to non-producing tracts. The court of appeals reversed. The Supreme Court reversed, holding (1) under the lease's special definition of drilling operations, activities other than spudding-in a well are sufficient to maintain the lease as to non-producing tracts; and (2) the record conclusively established that Lessee was engaged in a continuous drilling program within the meaning of the lease. View "Sundown Energy LP v. HJSA No. 3" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the claims in Plaintiffs' complaint against WM Capital Management, Inc. and granting summary judgment in favor of WM Capital on its counterclaim, holding that the district court did not err or abuse its discretion.This case arose from a dispute over the enforcement of a contract that controlled the liquidation and assignment of several mortgage notes. Plaintiffs initiated an action against WM Capital bringing claims for redemption of property and breach of contract. WM Capital filed a counterclaim seeking specific performance of the contract and joinder of Tenerife Real Estate Holdings, LLC, a signatory to the contract at issue. The district court joined Tenerife, dismissed Plaintiffs' complaint, and granted summary judgment for WM Capital on its counterclaim. The First Circuit affirmed, holding that the district court did not err. View "Almeida-Leon v. WM Capital Management, Inc." on Justia Law

In this dispute over who had the authority to lease shellfishing beds on behalf of the Town of Branford, the Supreme Court reversed the trial court's grant of summary judgment in favor of the Town, holding that summary judgment was improper.Plaintiffs had been granted the right of first refusal by Branford's Shellfish Commission to lease certain shellfishing grounds located in the Town, but the Commission leased the grounds to Plaintiffs' competitor. Plaintiff brought this action alleging breach of contract and promissory estoppel and that it enjoyed a right of first refusal. The Town moved for summary judgment, arguing that the right of first refusal was no a valid or enforceable contract because the Commission lacked authority to enter into it. The trial court agreed, holding that only the Town's Board of Selectmen had authority to lease the shellfishing beds on behalf of the Town. The Supreme Court reversed, holding that there was a genuine issue of material fact precluding summary judgment. View "Shoreline Shellfish, LLC v. Branford" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Business and Consumer Docket in favor of JJ Cars, LLC and John Mokarzel on H&B Realty, LLC's complaint for breach of contract, holding that there was no error in the court's judgment.The lower court determined that H&B breached the lease in this case by unreasonably withholding consent to a proposed sublease. On appeal, H&B argued that the court erred in applying the affirmative defenses, as pleaded by JJ Cars and Mokarzel, of breach of contract and failure to mitigate damages. The Supreme Judicial Court affirmed, holding that there was competent record evidence to support the court's finding that H&B materially breached the lease by refusing to consent to sublet the property. View "H&B Realty, LLC v. JJ Cars, LLC" on Justia Law