Justia Contracts Opinion Summaries
Articles Posted in Real Estate & Property Law
Edgar v. Mills
Thomas and Elizabeth Edgar entered into a lease agreement with Boyd and Merlyn Mills concerning land in Faulk County. Under the belief that he had an option to purchase the real estate at the conclusion of the lease term, Thomas Edgar later contacted an attorney to prepare a warranty deed so that the Millses could convey the real estate to the Edgars. After the Edgars’ attempts to execute the deed with the Millses failed, the Edgars sued the Millses for specific performance. The Millses counterclaimed, alleging that the Edgars breached the lease agreement. The trial court found the lease agreement ambiguous and considered parol evidence. The court ultimately concluded that the parties intended the lease agreement to be a lease with an option to purchase and ordered specific performance compelling the Millses to execute a warranty deed in favor of the Edgars. The Supreme Court reversed in part and remanded, holding (1) the trial court erred when it interpreted the parties’ agreement to be ambiguous and when it directed the Millses to execute a warranty deed in favor of the Edgars; and (2) under the lease, the Millses were entitled to reimbursement of their reasonable attorney’s fees incurred by reason of the Edgars’ breach of the lease agreement. View "Edgar v. Mills" on Justia Law
BP America Production Co. v. Laddex, Ltd.
In this case the trial court entered judgment terminating a bottom lease based on jury findings that the lease failed to produce in paying quantities over a specified period of time. The court of appeals reversed and remanded for a new trial, concluding (1) the rule against perpetuities did not invalidate the top lease, and (2) the trial court erred in charging the jury on the production-in-paying-quantities question. The Supreme Court affirmed, holding that the court of appeals correctly remanded for a new trial where (1) the top lease did not violate the rule against perpetuities; and (2) the trial court erred in charging the jury on cessation of production in paying quantities. View "BP America Production Co. v. Laddex, Ltd." on Justia Law
Lord & Taylor v. White Flint, L.P.
Lord & Taylor filed suit against White Flint, alleging breach of contract. Lord & Taylor operated a retail department store at the White Flint Shopping Center until White Flint closed the Mall and began demolition for a mixed use development. Lord & Taylor objected to the redevelopment, arguing that the clear terms of the parties' agreement required White Flint to maintain the Mall, and that the proposed mixed-use alternative would negatively affect its business. A jury found White Flint in breach of contract and awarded Lord & Taylor $31 million in damages. Both parties appealed. The court rejected White Flint's challenge to the damages award, concluding that the district court did not abuse its discretion by instructing the jury not to consider the potentially positive economic effects of the planned redevelopment in assessing damages for lost profits. Furthermore, the district court properly admitted a store executive's construction cost estimate as lay testimony. Finally, the court concluded that the district court committed no legal error or other abuse of discretion in applying long-established Maryland law to reject Lord & Taylor's claim to separate damages for the taking of property rights. Accordingly, the court affirmed the judgment. View "Lord & Taylor v. White Flint, L.P." on Justia Law
Global Quest v. Horizon Yachts
Plaintiff purchased a luxury yacht from Seller, the yacht was manufactured by Horizon and its wholly-owned subsidiary Premier in Taiwan, Horizon and Premier are Taiwanese companies, and Seller is an independent U.S. corporation based in Florida. Plaintiff filed suit, alleging ten claims related to the purchase of the yacht. The district court entered summary judgment for defendants on all but two claims: the breach of express warranty claims against Horizon and Premier; entered summary judgment for Seller on its counterclaim to foreclose on the promissory note; and certified the judgment as a partial final judgment for interlocutory review. On appeal, plaintiff challenged the entry of summary judgment as to: (1) the fraudulent inducement claims against all three defendants (Count I); (2) the breach of implied warranty claims against all three defendants (Counts III, IV, and VII); and (3) the breach of express warranty claim against Seller, Horizon Yachts, Inc. (Count VIII). The court vacated the district court's grant of summary judgment as to Counts I, III, IV, VII, and VIII and remanded for trial; affirmed the grant of summary judgment as to the remaining claims; and reversed the district court's grant of summary judgment on defendants' counterclaim. View "Global Quest v. Horizon Yachts" on Justia Law
deNourie & Yost Homes, LLC v. Frost
Homeowners obtained loans from Bank for the construction of a new home and entered into an agreement with Contractor to complete the new home construction. When Homeowners defaulted on payments owed to Contractor and on both loans, the house was sold at foreclosure, and Homeowners filed for bankruptcy. Contractor filed a fourth amended complaint against Homeowners, who were later dismissed as parties, and Bank. Following a trial the court granted summary judgment for Bank on Contractor’s claims of fraud and civil conspiracy. The Supreme Court reversed. After remand, Contractor filed a fifth amended complaint, which differed from the fourth amended complaint in several respects. The district court determined that the election of remedies doctrine and judicial estoppel required a dismissal of Contractor’s claims. The Supreme Court reversed, holding (1) Contractor’s claims were consistently premised on the existence of a contract, and therefore, no election was required; and (2) Contractor’s claims were based on different facts and obligations, and therefore, both could be pursued. View "deNourie & Yost Homes, LLC v. Frost" on Justia Law
Nicholson v. Coeur d’Alene Placer Mining Corp
This case was an appeal of a judgment: (1) denying recovery on an alleged oral promise to grant the Plaintiffs a right of first refusal with respect to a parcel of real property they were leasing; (2) denying recovery on an alleged oral promise to purchase the Plaintiffs’ buildings that were located on that property; and (3) finding that the Plaintiffs were guilty of unlawful detainer. Finding no reversible error, the Supreme Court affirmed the judgment. View "Nicholson v. Coeur d'Alene Placer Mining Corp" on Justia Law
Oklahoma ex rel. Dept. of Trans. v. Cedars Group, LLC
Prior to filing condemnation proceedings the Appellee Oklahoma Department of Transportation (ODOT) offered Appellants, Cedars Group, L.L.C., A. Sam Coury and Bush, Ltd. d/b/a Deer Creek Texaco, (collectively, Coury Defendants), $562,500.00 for the acquisition of certain real property. The offer was not accepted and ODOT commenced two condemnation proceedings. In one, a commissioners' report estimated the value of just compensation for the property to be $285,000.00. In the second proceeding, the value of just compensation was estimated as $177,500.00. The combined value of the two commissioners' awards totaled $462,500.00. The Coury Defendants hired Gregg Renegar's law firm to provide representation in the condemnation proceedings. Pursuant to the firm’s attorney-client agreement, the Coury Defendants agreed to pay forty percent of the difference between an award and jury verdict, plus any attorney’s fees allowed by the court. A jury trial was held, and the jury awarded just compensation of $525,000 for the two tracts. Defendants applied for attorney fees. The trial court determined Defendants were not entitled to an award of fees because they never actually incurred any. In the end, the trial court awarded appraisal fees but denied reasonable attorney, engineering and expert witness fees, costs and expenses of Defendants. The Supreme Court affirmed in part and reversed in part; the case was remanded for a determination of reasonable attorney fees, engineering and expert witness fees, and costs. View "Oklahoma ex rel. Dept. of Trans. v. Cedars Group, LLC" on Justia Law
Bank of America, N.A. v. Alexander
After the loan secured by Susan Alexander’s property went into default, Bank of America, N.A. (BANA) initiated foreclosure proceedings. The property was sold to BANA after a trustee’s sale. When Alexander refused BANA’s demand to vacate the property BANA filed a complaint for unlawful detainer against Alexander. Alexander asserted counterclaims for breach of contract, breach of an oral agreement, and frivolous litigation. The district court granted summary judgment in favor of BANA, concluding that the foreclosure sale was valid and that Alexander was unlawfully holding possession of the property. The court also concluded that Alexander’s counterclaims were either barred by the statute of limitations or statute of frauds and that there was a lack of supporting evidence for her claims. The Supreme Court affirmed, holding (1) BANA was entitled to summary judgment and a writ of assistance based on unlawful detainer; (2) Alexander failed to state a claim of fraud; (3) Alexander’s claims of breach of written or oral contract and breach of oral agreement were barred by the statute of limitations and statute of frauds; and (4) Alexander did not properly allege or offer supporting evidence for her claim of unjust enrichment. View "Bank of America, N.A. v. Alexander" on Justia Law
Beckstrand v. Beckstrand
Justin Beckstrand and James Beckstrand, through his surviving spouse, Cynthia, appealed a judgment awarding $164,202.40 in 2015 farm rental payments to Julie Beckstrand, the personal representative of John Beckstrand's estate. The Supreme Court found that because the district court's findings were inadequate to explain the basis for its equitable decision to award the farm rental payments to Julie Beckstrand, it reversed and remanded for the court to explain the rationale for its decision. View "Beckstrand v. Beckstrand" on Justia Law
Klein v. Sletto
Kevin and Lynn Klein appealed a judgment dismissing their claims and quieting title to certain real property in Gregory Sletto. The Supreme Court affirmed, concluding the district court did not err in granting summary judgment because the Kleins failed to present any evidence supporting their claims about the existence of a valid contract. View "Klein v. Sletto" on Justia Law