Justia Contracts Opinion Summaries

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

Plaintiffs filed suit alleging that pressure tactics used by Quicken Loans and TSI to influence home appraisers to raise appraisal values to obtain higher loan values on their homes constituted a breach of contract and unconscionable inducement under the West Virginia Consumer Credit and Protection Act. The district court granted summary judgment to plaintiffs.The Fourth Circuit concluded that class certification is appropriate and that plaintiffs are entitled to summary judgment on their claims for conspiracy and unconscionable inducement. However, the court concluded that the district court erred in its analysis of the breach-of-contract claim. The court explained that the district court will need to address defendants' contention that there were no damages suffered by those class members whose appraisals would have been the same whether or not the appraisers were aware of the borrowers' estimates of value—which one might expect, for example, if a borrower's estimate of value was accurate. The court agreed with plaintiffs that the covenant of good faith and fair dealing applies to the parties' contract, but concluded that it cannot by itself sustain the district court's decision at this stage. The district court may consider the implied covenant of good faith and fair dealing to the extent that it is relevant for evaluating Quicken Loans' performance of the contracts. Accordingly, the court affirmed in part and vacated and remanded in part. View "Alig v. Quicken Loans Inc." on Justia Law

The Supreme Court affirmed the order the circuit court certifying a class action against Defendants, holding that the circuit court did not err or abuse its discretion.Plaintiffs filed a class action complaint against Defendants, alleging, on their own behalf and on behalf of others similarly situated, that their water systems were contaminated with sewage due to Defendants' negligence. Plaintiffs moved for class certification. The circuit court certified the class as to their negligence and breach of contract claims. On appeal, Defendants argued that the circuit court erred in finding that class was ascertainable and that common issues predominated and erred in certifying the breach of contract claim. The Supreme Court affirmed, holding that the circuit court did not err in certifying the class. View "C.J. Mahan Construction Co. v. Betzner" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the circuit court entering judgment in favor of Thomas Wright on his claims for negligence, breach of contract, and deceit, holding that the circuit court erred in its damages award.Curtis Temple expressed interest in purchasing Wright's airplane and took the plane to his ranch, where it was damaged in a crash. When Wright's attempts to obtain compensation from Temple were unsuccessful, he brought suit. Temple also filed a third-party complaint against Ken Merrill, Temple's flight instructor, for negligence and contribution in the event Temple were to be found liable for damages. The jury found Temple liable to Wright on the claims of negligence, breach of contract, and deceit, and awarded damages. The jury also found Temple liable to Merrill but did not award damages to Merrill. The Supreme Court reversed in part and remanded the case for a new trial on the limited issue of damages, holding (1) there was sufficient evidence to support the finding that Temple breached a contract between Temple and Wright; (2) there was sufficient evidence to support the finding that Temple was negligent; and (3) the circuit court erred in instructing the jury on damages and in determining the total award. View "Wright v. Temple" on Justia Law

In this partition action, the Supreme Court vacated the judgment of the superior court ruling that Plaintiff's death terminated her interest in a joint tenancy, holding that R.I. Gen. Laws 34-15-12 abrogates the common law right of survivorship in a joint tenancy when an action for partition is pending.Plaintiff filed a partition action requesting that the superior court partition property she owned in a joint tenancy with Defendants. Defendants asserted counterclaims for unjust enrichment and breach of agreement. While the litigation was pending, Plaintiff died. Defendants moved to dismiss the partition action, asserting that Plaintiff's property interest had passed to the remaining joint tenants by operation of law upon Plaintiff's demise. The hearing justice granted the motion. The Supreme Court vacated the judgment, holding that Plaintiff's decease did not abate her action for partition, and therefore, the litigation remained pending. View "Butler v. Gavek" on Justia Law

The Supreme Court affirmed the judgment of the district court granting various mortgage lenders and trustees summary judgment on Plaintiff's claims for negligence and breach of the implied covenant of good faith and fair dealing, holding that genuine issues of material fact did not preclude summary judgment.Plaintiff filed an action asserting negligent loan supervision/administration, breach of the implied contract covenant of good faith and fair dealing, anticipatory declaratory judgment, and quiet title to mortgaged property. The district court granted summary judgment to Bank of America, N.A. (BOA) on all claims. The Supreme Court affirmed, holding that the district court did not err in granting BOA summary judgment on Plaintiff's asserted negligence and breach of the implied covenant of good faith and fair dealing claims. View "House v. U.S. Bank National Ass'n" on Justia Law