Justia Contracts Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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After Strine Printing Company terminated Richard Bisbano’s employment, Bisbano filed an eight count complaint against Strine Printing and its president, alleging, inter alia, wrongful termination. During the pendency of that lawsuit, the parties disagreed about the exact amount of commissions that Strine owed Bisbano. The federal district court granted Defendants’ motion for summary judgment on all counts. Bisbano subsequently filed another lawsuit against Strine Printing and Menasha Packaging Company, LLC in superior court, alleging unpaid commissions. The trial justice ruled in favor of Defendants, concluding that the three-year statute of limitations contained in Rhode Island’s Payment of Wages Act barred the claim and that res judicata barred Bisbano’s contract claims. The Supreme Court affirmed, holding (1) this action was barred by the statute of limitations contained in the Payment of Wages Act; and (2) because the statute of limitations issue is dispositive, the Court shall not address the issue of res judicata. View "Bisbano v. Strine Printing Co., Inc." on Justia Law

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After a jury-waived trial, the trial justice entered judgment in favor of Defendant on Plaintiff’s breach of contract claim. The justice also entered judgment in favor of Defendant on his counterclaim for conversion. Plaintiff appealed the adverse rulings and also appealed the denial of her post-trial motion for relief from the superior court judgment, which motion invoked Rule 60(b) of the Superior Court Rules of Civil Procedure. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) determining that there was no contract; (2) finding in Defendant’s favor on his conversion counterclaim; and (3) dismissing Plaintiff’s Rule 60(b) motion. View "Turdo v. Main" on Justia Law

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Defendant, an attorney, represented Plaintiff in post-final judgment divorce proceedings. Defendant later withdrew as counsel with the family court’s approval. Three years later, Plaintiff filed a complaint against Defendant, alleging legal malpractice, negligence, fraud, and breach of fiduciary duty. The superior court entered summary judgment in favor of Defendant on each of Plaintiff’s claims. The Supreme Court affirmed, holding (1) Plaintiff’s legal malpractice and fraud claims were barred by the statute of limitations, and the trial justice did not err in concluding that the discovery rule did not toll the statute of limitations; (2) Plaintiff’s malpractice claims necessarily failed because she did not retain an expert witness to testify in support of her case; and (3) Plaintiff’s remaining claims on appeal were wholly without merit. View "Behroozi v. Kirshenbaum" on Justia Law

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Sophie Danforth entered into a purchase and sales agreement (PSA) with Timothy and Rebecca More, pursuant to which Danforth agreed to sell, and the Mores agreed to purchase, certain real estate. The PSA provided that $30,000 would be paid as a deposit at the time the PSA was executed. The Mores failed to appear at the scheduled closing. Thereafter, Danforth filed an amended complaint alleging breach of contract, requesting that she be allowed to retain the Mores’ deposit, and seeking declaratory relief, asking the court to construe the terms of the PSA and to order the escrow agent to disburse the deposit to Danforth. The hearing justice granted summary judgment in favor of Danforth, concluding that Danforth was entitled to retain the deposit. The court further denied Danforth’s motion for attorney’s fees but awarded prejudgment interest. The Supreme Court affirmed, holding that there was no error in the grant of summary judgment in favor of Danforth, the award of prejudgment interest to Danforth, and the denial of attorneys’ fees. View "Danforth v. More" on Justia Law

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Defendant agreed to furnish labor, materials, equipment, and services for a pipe-replacement project at Brown University. Defendant entered into a sub-contract with Plaintiff in which Plaintiff agreed to install the pipe. After Plaintiff completed its portion of the project, Plaintiff filed breach of contract and quantum meruit claims against Defendant, alleging that Defendant failed to pay for some of the work that Plaintiff performed on the project. The superior court entered judgment in favor of Plaintiff on its quantum meruit claim. The Supreme Court affirmed, holding that the trial justice did not misapply the law, misconceive or overlook material evidence, or make factual findings that were clearly wrong in reaching its decision. View "Process Eng'rs & Constructors, Inc. v. DiGregorio, Inc." on Justia Law

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Lawrence LaBonte, the owner of New England Development RI, LLC (N.E. Development), filed a petition seeking the reorganization and/or the dissolution of N.E. Development. American Steel Coatings, LLC (American Steel) filed a motion to approve secured claim attempting to recover the funds it alleged were owed pursuant to a loan agreement between the parties. The LLC’s permanent receiver and LaBonte objected to American’s motion, asserting that the loan agreement was void because the amount of interest to be charged violated the state’s usury laws. The superior court sustained the objections and voided as usurious the loan agreement. The Supreme Court affirmed, holding that the loan agreement in this case was usurious and, therefore, void. View "LaBonte v. New England Dev. R.I., LLC" on Justia Law

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Plaintiff-general contractor entered into an agreement with Defendant-subcontractor to perform work on a project. A dispute arose between the parties when Plaintiff issued Defendant a notice of termination. The issue was submitted to arbitration, and both parties submitted claims to the arbitrator for money damages. The arbitrator found that Plaintiff’s termination of Defendant was wrongful and granted damages. Plaintiff sought to vacate the arbitrator’s award. The trial court concluded that a release signed by Defendant that waived all claims prior to a certain date barred Defendant’s claims. The Supreme Court vacated the judgment of the superior court, holding that the arbitrator’s decision should have been allowed to stand because it showed due regard for the parties’ release and did not reach an irrational result. View "Berkshire Wilton Partners, LLC v. Bilray Demolition Co." on Justia Law

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At issue in this case was which party was entitled to insurance funds under an insurance policy on a parcel of property that sustained water damage. Stanley Gurnick and Phoenix-Gurnick, RIGP claimed they owned the property as a result of a foreclosure sale. Navigant Credit Union claimed it was entitled to the funds as the named mortgagee/loss payee in the insurance policy. The superior court decided that Navigant was entitled to the insurance proceeds because the funds were personal property under the insurance contract and Navigant was named a loss payee under that contract. The Supreme Court affirmed, holding that the hearing justice correctly determined that Navigant was entitled to the insurance proceeds. View "R.I. Joint Reinsurance Ass'n v. O'Sullivan" on Justia Law

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Plaintiffs agreed to lease medical diagnostic imaging equipments to Defendants for use in a medical imaging center. The center proved to be unsuccessful shortly after it opened, and Defendants defaulted on their payments. Plaintiffs filed a fourteen-count complaint against Defendants that included counts for replevin, breach of contract, breach of consent to sublease, and breach of sublease. Defendants counterclaimed for intentional misrepresentation, negligent misrepresentation, fraud and deceit, and a violation of Mass. Gen. Laws ch. 93A. The superior court granted summary judgment for Plaintiffs on all claims and counterclaims. The Supreme Court affirmed, holding that there were no genuine issues of material fact, and therefore, summary judgment was proper on Plaintiffs’ claims and Defendants’ counterclaims. View "Siemens Fin. Servs., Inc. v. Stonebridge Equip. Leasing, LLC " on Justia Law

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Plaintiffs purchased a home that a pre-closing inspection revealed had corrosion on the oil heating system in the basement. Although the boiler and oil tank were replaced prior to the sale of the home, the oil feed line buried beneath the concrete floor in the basement was not replaced. After Plaintiffs discovered an oil leak at the feed line, they initiated claims under their homeowners’ insurance policy issued by Defendant. Defendant denied Plaintiffs’ claim. Plaintiffs filed a complaint against Defendant for breach of contract. The trial justice granted summary judgment in favor of Defendant, concluding that Plaintiffs’ claim was caused by gradual corrosion of an oil fuel feed line, not by a sudden or accidental loss, and the claim was therefore barred by the clear and unambiguous terms of the policy. The Supreme Court affirmed, holding that because the undisputed evidence indicated that the damage to Plaintiffs’ property was caused by corrosion, which was not covered by their insurance policy, there were no genuine issues of material fact, and Defendant was entitled to judgment as a matter of law. View "Nunez v. Merrimack Mut. Fire Ins. Co." on Justia Law