Justia Contracts Opinion Summaries

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) in this litigation concerning a dispute arising from a 1999 contract regarding the sale of approximately twenty-three acres of land in Honualua Maui, holding the the ICA erred by holding that Wailea Resort Company was clearly entitled to certain funds but otherwise did not err.The parties in this consolidated appeal were Michael Szymanski, Wailea, and ADOA-Shinwa Development and Shinwa Golf Hawai'i Company (collectively, Shinwa). Szymanski filed this application seeking a writ of certiorari raising seven questions. The Supreme Court held (1) the questions relating to the disqualification of the Honorable Rhonda I.L. Loo were without merit; (2) the ICA did not err in its application of the law of the case doctrine to the issue of whether the ICA gravely erred when it declined to review whether the Honorable Peter T. Cahill's 2015 order entering final judgment improperly dismissed with prejudice Szymanski's third-party complaint against Shinwa; and (3) the ICA erred by holding that Wailea was clearly entitled to certain funds and by affirming the circuit court's disbursal of funds. View "Title Guaranty Escrow Services, Inc. v. Wailea Resort Co., Ltd." on Justia Law

The Supreme Court affirmed the judgment of the district court denying GFTLenexa, LLC relief in an action based on contractual relationships but brought as an inverse condemnation proceeding, holding that there was no error in the reasoning or conclusions of the district court.GFTLenexa, LLC alleged in this action that a condemnation through an eminent domain action resulted in GFTLenexa's intangible property rights being damaged. The action was predicated on its reduced rental income because of an action that it lost to its sublessee involving the condemnation. The district court denied summary judgment to GFTLenexa. The Supreme Court affirmed, holding the proper venue for GFTLenexa to assert its rights was in the eminent domain proceeding, even if it could not have successfully asserted them there because it surrendered its rights through its contractual obligations. View "GFTLenexa, LLC v. City of Lenexa" on Justia Law

In this dispute over credit provisions in a real estate purchase agreement, the Supreme Court reversed the decision of the court of appeals reversing the trial court's grant of summary judgment in favor of Plaintiff, the buyer of a franchise business and the real property on which it sat, holding that the court of appeals erred.The parties in this case structured the agreement for the sale of the real property to include adjustments that would be made to the overall purchase price based on circumstances present at the time of the closing. At closing, the parties disagreed how one of the credit provisions - the Rents Credit - should be interpreted. The trial court granted summary judgment to Plaintiff as to its request for declaratory judgment interpreting the Rents Credit clause. The court of appeals ultimately reversed, concluding that the plain language of the Rents Credit clause led to a "manifestly absurd result." The Supreme Court reversed, holding (1) the language of the Rents Credit is plain and unambiguous and supports only the interpretation asserted by Plaintiff; and (2) there is no basis on which to conclude that the plain language of the Rents Credit results in a manifest absurdity. View "Beverage Holdings, LLC v. 5701 Lombardo, LLC" on Justia Law

This appeal stemmed from an unlawful-detainer and breach-of-contract action filed by Caldwell Land and Cattle, LLC, (“CLC”) after purchasing a building where the holdover tenant, Johnson Thermal Systems (“JTS”), asserted a right to remain on the property. The dispute centered on the interpretation of a lease between JTS and the original property owner which granted JTS an option to extend the lease. JTS contended it properly exercised the option; CLC contends JTS did not. The district court held that JTS failed to exercise the option and thus became a holdover tenant. The court further held that when JTS did not vacate within the proper timeframe, JTS unlawfully detained the premises and was liable for the ensuing damages. JTS appealed, but finding no reversible error, the Idaho Supreme Court affirmed. The district court’s amended final judgment and its order of attorney’s fees was remanded, however, for reentry of damages consistent with the Supreme Court’s opinion , and for reconsideration of attorney’s fees. View "Caldwell Land & Cattle v. Johnson Thermal" on Justia Law

The Supreme Court vacated the judgment of the district court in this action alleging breach of contract, conversion, and tortious interference with a business relationship of expectation, holding that Plaintiff lacked standing to bring the action in his own name.Kim Hawley, the only named plaintiff, brought this action against John Skradski alleging that he purchased a heating and air conditioning (HVAC) business from an entity affiliated with Skradski and that, after Hawley ceased operating the business, Skradski began operating the business and converted the business's assets to his use. During trial, an asset purchase agreement was received into evidence showing that the HVAC business was purchased by KNR Capital Corp. and not by Hawley individually. The district court granted Skradksi's motion for a directed verdict, finding that there was insufficient evidence of any of the three theories of recovery. The Supreme Court vacated the district court's judgment and dismissed the appeal for lack of subject matter jurisdiction, holding that Hawley failed to prove his standing to bring this suit in his own name, and therefore, the district court lacked subject matter jurisdiction over the matter. View "Hawley v. Skradski" on Justia Law

In this appeal from ongoing litigation involving adjoining property owners the Supreme Judicial Court vacated the motion judge's order denying plaintiff developer's special motion to dismiss defendant abutters' counterclaims, holding that the abutters could not demonstrate that their claims were not strategic lawsuits against public participation (SLAPP suits).The developer filed a complaint against the abutters alleging abuse of process and violation of Mass. Gen. Laws ch. 93A. Both parties were then involved in motions filed under the anti-SLAPP act, Mass. Gen. Laws ch. 231, 59H. Here, the developer appealed from the denial of its special motion to dismiss the abutters' counterclaims alleging breach of the implied covenant of good faith and fair dealing, abuse of process, and violation of chapter 93A. The Supreme Judicial Court remanded the case for entry of an order allowing the special motion to dismiss, holding (1) none of the abutters' contract-based counterclaims was colorable; and (2) the abutters failed to demonstrate that any of their remaining counterclaims were not retaliatory. View "477 Harrison Avenue, LLC v. JACE Boston, LLC" on Justia Law

A storm caused minor hail damage at the Winding Ridge condominium complex located in Indiana, which was not discovered until almost a year later when a contractor inspected the property to estimate the cost of roof replacement. Winding Ridge submitted an insurance claim to State Farm. The parties inspected the property and exchanged estimates but could not reach an agreement. Winding Ridge demanded an appraisal under the insurance policy. State Farm complied. After exchanging competing appraisals, the umpire upon whom both sides agreed issued an award, which became binding. Winding Ridge filed suit alleging breach of contract, bad faith, and promissory estoppel. The Seventh Circuit held that the appraisal clause is unambiguous and enforceable; there is no evidence that State Farm breached the policy or acted in bad faith when resolving the claim. Winding Ridge’s own appraiser found no hail damage to the roofing shingles on 20 buildings. The fact that Winding Ridge independently replaced the shingles on all 33 buildings for $1.5 million while its claim was pending does not obligate State Farm under the policy or mean State Farm breached the policy. There is no evidence that State Farm delayed payment, deceived Winding Ridge, or exercised an unfair advantage to pressure Winding Ridge to settle. View "Villas at Winding Ridge v. State Farm Fire and Casualty Co." on Justia Law

Plaintiffs, Lofts Essex, LLC and the Wilson Inn, Inc. (collectively, the Lofts), appeal the trial court’s pretrial denial of summary judgment and the court’s final decision ruling in favor of defendant, Strategis Floor and Décor, Inc. The dispute between the parties arose from a warranty claim made on laminate flooring in a 54-apartment unit complex. The Vermont Supreme Court concluded that the trial court’s pretrial denial of summary judgment was not reviewable and affirmed the final decision granting judgment to Strategis. View "The Lofts Essex, LLC v. Strategis Floor Decor Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Plaintiffs' claims against home builder gravestone Homes, Inc. seeking tort and contract remedies after mold developed in a new home, holding that the circuit court erred in dismissing negligent-repair claims and contract claims.George and Crystal Tingler entered into a construction contract with Graystone to construct a new home on property owned by a family-run company, Belle Meade Farm, LLC. After the house was built, rain water leaked into the house, and mold developed. Graystone tried unsuccessfully to remediate the mold. The Tinglers and their children subsequently abandoned the home and sued Graystone seeking contract remedies for roperty damage, personal injuries, and economic losses. The Tinglers and Belle Meade separately sued Graystone seeking contract remedies for economic losses and property damage. The circuit court dismissed all claims in each of the complaints. The Supreme Court reversed in part, holding that the circuit court erred (1) in dismissing the negligent-repair counts in the Tingler family's personal injury complaints and the Tinglers' and Belle Meade's complaint; and (2) in dismissing the contract claims and contractual claims in the Tinglers' and Belle Meade's complaint. View "Tingler v. Graystone Homes, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the court of appeals' judgment reversing the district court's judgment dismissing Plaintiffs' claim for, inter alia, product liability, holding that the Kansas Product Liability Act, Kan. Stat. Ann. 60-3301 et seq., does not subsume or extinguish any legally viable alternative cause of action seeking recovery for direct or consequential economic loss.After Plaintiffs built thousands of homes they installed bathroom ceiling fans constructed by Defendants. Several ceiling fans caught fire and damaged several homes. Plaintiffs removed and replaced the remaining fans and then brought this lawsuit asserting several claims, including claims for product liability. The district court concluded that the economic loss doctrine barred Plaintiffs from recovery. The court of appeals reversed, holding that the economic loss doctrine did not bar Plaintiffs from asserting a product liability claim because the property damage to the homes was not economic loss. The Supreme Court reversed in part, holding (1) the court of appeals properly reversed the summary judgment with respect to any property damage; and (2) because it cannot be discerned whether some or all of the claims Plaintiffs claimed as removal and replacement damages were legally recoverable in an unjust enrichment cause of action, the case must be remanded. View "Corvias Military Living, LLC v. Ventamatic, Ltd." on Justia Law