Justia Contracts Opinion Summaries

Active Spine Physical Therapy, LLC (Active Spine) and its owners, Sara and Nicholas Muchowicz, were sued by 132 Ventures, LLC (Ventures) for breach of contract and personal guarantee after failing to pay rent and common area maintenance (CAM) charges under a lease agreement. Ventures had purchased the property in a foreclosure sale and sought damages for unpaid rent and CAM charges from June 2020 to February 2021. Active Spine argued that the lease was invalid due to fraudulent inducement and that they were under a COVID-19-related rent abatement.The district court initially ordered restitution of the premises to Ventures and denied Active Spine's request for a temporary injunction. A separate bench trial found Active Spine and the Muchowiczes liable for breach of contract. On appeal, the Nebraska Supreme Court affirmed the restitution order but reversed the breach of contract judgment, remanding for a jury trial.At the jury trial, Ventures presented evidence of unpaid rent and CAM charges, while Active Spine argued that Ventures failed to provide notice of budgeted direct expenses, a condition precedent to their obligation to pay CAM charges. The jury found in favor of Ventures, awarding $593,723.82 in damages. Active Spine and the Muchowiczes moved for a new trial or judgment notwithstanding the verdict (JNOV), arguing errors in the jury's damage calculations and the lack of notice of budgeted direct expenses.The Nebraska Supreme Court reviewed the case and found that the district court did not abuse its discretion in admitting the exhibits as business records and not summaries under Neb. Rev. Stat. § 27-1006. The court also held that Active Spine and the Muchowiczes failed to preserve their arguments for appeal regarding the costs of new tenancy, COVID-19 abatement, and the amended lease. The court affirmed the district court's denial of the motion for new trial or JNOV, concluding that the jury's verdict was supported by sufficient evidence. View "132 Ventures v. Active Spine Physical Therapy" on Justia Law

Mary Johnson entered into an oral agreement with her parents, Carl and Pearl Johnson, to obtain financing for constructing a small home on a parcel of land (Gertie Lode) they conveyed to her. In exchange, Mary and her family could live in their parents' larger home on a separate parcel (Spaniard Lode). Once the mortgage was satisfied, Mary was to transfer the Gertie Lode property equally to herself and her siblings. Despite satisfying the mortgage, Mary informed her siblings in 2008 that she would not convey the land to them.Greg Johnson, Mary's brother, sought to enforce the oral agreement and reform the deed from their parents to Mary. The Circuit Court of the Seventh Judicial Circuit, Pennington County, granted Mary’s motion for summary judgment, determining that Greg’s breach of contract claim was barred by the statute of limitations and that he was not entitled to reformation because he could not establish that the deed failed to reflect the parties’ intent. Greg appealed the decision.The Supreme Court of the State of South Dakota reviewed the case and affirmed the lower court's decision. The court held that Greg’s breach of contract claim accrued when he received Mary’s 2008 letter, which clearly indicated her intent to breach the oral agreement. Since Greg did not bring his claim until October 2018, it was barred by the six-year statute of limitations. Additionally, the court found no basis for reformation of the deed, as the oral agreement was never reduced to writing, and the warranty deed accurately reflected the intent of the parties. Therefore, summary judgment on both the breach of contract and reformation claims was appropriate. View "Johnson v. Johnson" on Justia Law

Northstar Center, LLC filed a lawsuit against Lukenbill Family Partnership, LLLP, and Tundra Properties, LLC, alleging breach of contract and intentional interference with contract. Lukenbill had initially agreed to sell a 120-acre parcel to Templeton Enterprises, LLC, which later assigned its rights to Northstar. However, Lukenbill sold the property to Tundra instead. Northstar claimed Lukenbill breached their agreement, and Tundra intentionally interfered with the contract. Lukenbill sought indemnification from Tundra, and Tundra counterclaimed for breach of warranty deed against Lukenbill.The District Court of Williams County granted summary judgment in favor of Northstar on its breach of contract and intentional interference claims, and in favor of Lukenbill on its indemnification claim against Tundra. The court denied Tundra’s summary judgment motion on its breach of warranty claim against Lukenbill, concluding Tundra did not adequately brief the issue.The North Dakota Supreme Court reviewed the case and found that the district court erred in granting summary judgment for Northstar on its breach of contract and intentional interference claims, as genuine issues of material fact existed. The court also found that the district court erred in granting summary judgment for Lukenbill on its indemnification claim against Tundra. However, the Supreme Court affirmed the district court’s dismissal of Tundra’s breach of warranty claim against Lukenbill, as Tundra did not challenge the dismissal on the grounds that it could not maintain the claim without a certificate of authority to transact business in North Dakota.The North Dakota Supreme Court affirmed in part, reversed in part, and remanded the case for further proceedings consistent with its opinion. View "Northstar Center v. Lukenbill Family Partnership" on Justia Law

TCR, LLC, a Wyoming limited liability corporation, filed a lawsuit against Teton County, Idaho, after the County refused to record a Condominium Plat for property within a planned unit development (PUD) owned by TCR. TCR sought declaratory and injunctive relief, claiming the lot had already been approved for condominium development, and also alleged breach of a 1996 settlement agreement between the County and TCR’s predecessor. The district court granted TCR’s motion for summary judgment on the declaratory and injunctive relief claim, ordering the County to record the Condominium Plat, but granted the County’s motion for summary judgment on the breach of contract claim.The district court found that the County had previously approved amendments to the PUD Plat in 2018 and 2019, allowing TCR to build sixteen standalone condominiums on Lot 12B. The County’s refusal to record the Condominium Plat was based on an alleged site plan from 1995, which the district court found inadmissible. The district court concluded that the County had no legal basis to refuse the recording and enjoined the County from preventing TCR’s attempts to record the Plat.The Supreme Court of Idaho affirmed the district court’s decision to grant TCR’s claim for declaratory and injunctive relief, holding that the County had no valid reason to refuse the recording. However, the Supreme Court reversed the district court’s grant of summary judgment to the County on the breach of contract claim, finding that there were genuine issues of material fact regarding whether the County breached the 1996 Settlement Agreement. The case was remanded for further proceedings on this issue.The Supreme Court also found that the district court erred in denying TCR’s second motion to enforce, which sought to compel the County to issue building permits after the Condominium Plat was recorded. The Court awarded TCR its attorney fees and costs on appeal, concluding that the County acted without a reasonable basis in fact or law. View "TCR, LLC v. Teton County" on Justia Law

Casey and Janae Ruppert entered into a contract to purchase ranch property from Judith Merrill. Before closing, Merrill indicated she would not proceed with the sale. The Rupperts filed a complaint seeking specific performance and damages. The district court found Merrill breached the contract and denied her affirmative defenses. It awarded the Rupperts damages and attorneys’ fees but declined to order specific performance. The Rupperts appealed the denial of specific performance, and Merrill cross-appealed the attorneys’ fees award.The District Court of Laramie County found Merrill breached the contract but declined to order specific performance, citing Merrill’s personal circumstances and misunderstandings about the contract. It awarded the Rupperts $22,342 in damages and granted their motion for attorneys’ fees without explanation, awarding $55,258.50 in fees and $3,082.60 in costs.The Wyoming Supreme Court reviewed the case and found the district court abused its discretion by denying specific performance. The court noted the district court’s findings contradicted its decision, as it found the contract valid, the price reasonable, and no undue influence or unconscionability. The Supreme Court held that specific performance was the appropriate remedy given the circumstances and the equities involved.Regarding attorneys’ fees, the Supreme Court agreed with both parties that the district court erred by awarding fees without explanation. The Supreme Court independently assessed the reasonableness of the fees, concluding that the rates charged were excessive for the local market. It reduced the hourly rate to $250, resulting in a total fee award of $28,425.00, plus the previously awarded costs of $3,082.60.The Wyoming Supreme Court reversed the district court’s orders denying specific performance and awarding attorneys’ fees, remanding the case for entry of an order consistent with its opinion. View "Merrill v. Ruppert" on Justia Law

Fitzgerald Fruit Farms, LLC leased land from Whitaker Farms, LLC for a peach orchard. After being locked out of the leased premises, Fitzgerald Farms sued Whitaker Farms for damages. A jury awarded compensatory damages to Fitzgerald Farms. The Court of Appeals affirmed in part but reversed the trial court’s ruling that Fitzgerald Farms could not seek punitive damages. On remand, a second jury awarded punitive damages to Fitzgerald Farms. The Court of Appeals affirmed, holding that statements made during a settlement negotiation by Whitaker Farms’s Chief Operating Officer to Fitzgerald Farms’s owner were properly admitted under OCGA § 24-4-408.The trial court initially ruled that Fitzgerald Farms could not seek punitive damages, but the Court of Appeals reversed this decision. On remand, the trial court conducted a second jury trial focused on punitive damages, where the jury awarded $500,000 in punitive damages to Fitzgerald Farms. Whitaker Farms appealed again, arguing that the trial court abused its discretion by admitting statements made during a settlement negotiation. The Court of Appeals affirmed the trial court’s decision, stating that the statements were admissible to show Whitaker’s intent and state of mind.The Supreme Court of Georgia reviewed the case and vacated the Court of Appeals’s judgment. The Supreme Court determined that the statements made during the settlement negotiation were inadmissible under OCGA § 24-4-408. The Court concluded that the statements were offered to prove Whitaker Farms’s liability for punitive damages, which is not permissible under the statute. The case was remanded to the Court of Appeals to determine whether the admission of the statements was harmful and if a new trial on punitive damages is required. View "Whitaker Farms, LLC v. Fitzgerald Fruit Farms, LLC" on Justia Law

This case involves a dispute over two adjacent properties, each containing a multi-unit apartment complex with on-site parking. The plaintiffs, Eli and Maha Batta, sought to establish easement rights for additional parking and trash dumpsters on a disputed area of the adjacent property owned by the defendant, Therese Hunt. The Battas purchased their property from Hunt in 1994 and claimed that their tenants had used the disputed area for parking and dumpsters since then. Hunt refused to sign a parking covenant in 2019, leading the Battas to file a lawsuit seeking to quiet title to an easement by grant, prescription, or irrevocable license, and for breach of contract.The Superior Court of Los Angeles County conducted a bench trial and ruled in favor of the Battas, finding they had established easement rights by oral grant, prescription, and implication. The court ordered that the easement would expire upon a bona fide sale of either property. Both parties appealed the decision. Hunt argued that the trial court erred in granting the easement rights, while the Battas contended that the court abused its discretion by ruling that the easement would expire upon a sale.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case and found that the trial court's findings were inconsistent. The trial court had found both that Hunt had granted an easement and that the Battas' use of the property was adverse, which are mutually exclusive conditions. The appellate court concluded that these inconsistent findings required reversal. Additionally, the appellate court found that the trial court abused its discretion by allowing the Battas to amend their complaint to add a cause of action for an easement by implication without giving Hunt the opportunity to rebut the evidence. Consequently, the judgment was reversed and the case was remanded for further proceedings. View "Batta v. Hunt" on Justia Law

Vernon K. Stensvad, the plaintiff, owns a small cattle herd and entered into a Grazing Lease Contract with Newman Ayers Ranch, Inc. in July 2022. The contract stipulated that Stensvad would graze his cattle on Ayers Ranch's property for a fee, with higher winter rates to be determined. Stensvad paid the fees for July and August but later agreed orally to perform labor in exchange for reduced fees. Disputes arose over the quality of Stensvad's work and the amount owed. In October 2023, Ayers Ranch issued an agister’s lien for $78,662.50, seizing Stensvad’s herd. Stensvad sought a preliminary injunction to prevent the sale of his cattle under the lien.The Seventh Judicial District Court in Prairie County granted Stensvad’s application for a preliminary injunction, ordering the cattle to be moved to a third-party feed lot. Ayers Ranch appealed, arguing that the District Court failed to consider all four factors required for a preliminary injunction under Montana law and that a preliminary injunction was not an appropriate remedy for challenging an agister’s lien.The Montana Supreme Court reviewed the case and held that the District Court manifestly abused its discretion by not addressing all four factors of the preliminary injunction standard. The Supreme Court clarified that under the revised standard, a party must satisfy all four factors: likelihood of success on the merits, likelihood of irreparable harm, balance of equities, and public interest. The Court adopted the "serious questions" test from the Ninth Circuit, allowing for flexibility in evaluating these factors. The case was remanded for the District Court to make supplemental findings consistent with this standard. The Supreme Court also held that a preliminary injunction is an appropriate remedy to challenge an agister’s lien and that Stensvad did not have an adequate remedy at law. View "Stensvad v. Newman Ayers Ranch" on Justia Law

The case involves a dispute over a real estate transaction between Francesco Scotti and Matthew Mimiaga concerning a property at 300 Benefit Street in Providence, Rhode Island. In 2015, Scotti sold the property to Mimiaga, who financed the purchase through a promissory note. As part of the transaction, Scotti was granted an option to repurchase the property within five years for $900,000. Scotti claimed he exercised this option by mailing a handwritten letter to Mimiaga on June 1, 2020, but Mimiaga denied receiving it. Scotti also alleged that Mimiaga requested extensions to stay on the property due to COVID-19 and other issues, which he granted.The Superior Court granted summary judgment in favor of Mimiaga, ruling that the option agreement lacked separate consideration, Scotti did not properly exercise the option, and there was no express or implied waiver of the option's terms. The court found no evidence that Mimiaga received the June 1, 2020 letter and concluded that Scotti did not act timely to repurchase the property.The Rhode Island Supreme Court reviewed the case and vacated the Superior Court's judgment. The Supreme Court held that the option agreement was supported by consideration as stated in the written document. It also found that a genuine issue of material fact existed regarding whether Mimiaga received the June 1, 2020 letter, invoking the presumption that mailed notices are received. Additionally, the court determined that whether time was of the essence and whether there was an implied waiver of the option's terms were genuine issues of material fact that precluded summary judgment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Scotti v. Mimiaga" on Justia Law

Hexagon US Federal, Inc. ("HexFed") leased a portion of a building from Intergraph Unimproved Properties, LLC in 2015. The lease included two bays with different terms and renewal options. In 2016, the lease was amended to provide a five-year term for both bays. CBS Holdings, LLC later acquired the building and the lease. A dispute arose over whether HexFed had validly renewed the lease, leading HexFed to file a lawsuit against CBS Holdings for breach of the lease agreement.The Madison Circuit Court held a bench trial and ruled in favor of HexFed, finding that CBS Holdings had waived its right to argue that the lease for one of the bays had expired after 12 months. The court also reformed the lease to correct a mutual mistake, establishing that the maximum monthly rent for the bay did not expire after one year. The court declared that HexFed had properly exercised its renewal option and awarded HexFed costs and attorneys' fees.The Supreme Court of Alabama reviewed the case and affirmed the lower court's judgment. The court held that CBS Holdings had waived its argument about the lease term by accepting rent without objection and by executing a lease amendment without changing the lease term. The court also upheld the reformation of the lease, finding clear evidence of a mutual mistake. Additionally, the court agreed that HexFed had validly renewed the lease by providing timely written notice, despite an error in the rent calculation. Finally, the court affirmed the award of costs and attorneys' fees to HexFed, as it was forced to file the action to enforce the lease. View "CBS Holdings, LLC v. Hexagon US Federal, Inc." on Justia Law