Justia Contracts Opinion Summaries

Willie C. Scott signed a promissory note on May 22, 2018, promising to pay $67,000 to Jimmy C. Scott by March 24, 2020. The note detailed amounts borrowed on three separate dates. Willie passed away on November 20, 2019, and Jeanetta C. Scott, as administratrix of his estate, denied the allegations in Jimmy's complaint, asserting that Willie had fulfilled his obligations under the note.Jimmy filed a complaint in the Pike Circuit Court on October 13, 2021, seeking repayment. Jeanetta contested the claim, and the case was consolidated with another related to the administration of Willie's estate. Jimmy moved for summary judgment, supported by affidavits from himself and two witnesses who attested to witnessing Willie sign the note. Jeanetta opposed the motion, providing affidavits from herself and another individual, both asserting that the signature on the note was not Willie's.The Pike Circuit Court initially denied Jimmy's motion for summary judgment but later granted it after a renewed motion and hearing. Jeanetta's subsequent motion to set aside the summary judgment was denied, leading to this appeal.The Supreme Court of Alabama reviewed the case and found that the circuit court had improperly made credibility assessments in granting summary judgment. The court noted that there was a genuine issue of material fact regarding the authenticity of Willie's signature on the promissory note, which should be resolved by a jury. Consequently, the Supreme Court of Alabama reversed the circuit court's summary judgment in favor of Jimmy and remanded the case for further proceedings. View "Scott v. Scott" on Justia Law

Jill Brenden appealed an order from the Eighteenth Judicial District Court, Gallatin County, which denied her claims against the estate of her late husband, Robert Brenden. Jill sought reimbursement for expenses and objected to the distribution and valuation of certain property in the estate. Barbara Jensen, Robert's sister and the appellee, sought attorney fees. Jill and Robert had a long-term relationship, cohabitated, and married in 2010. They purchased a home together in 2006 and later built another home on a property Robert inherited. Robert was diagnosed with cancer, which went into remission but later returned. Before his death, Robert designated Barbara as the Payable on Death (POD) beneficiary of his bank account.The District Court found that Jill converted funds from Robert's account after his death, despite her claim that Robert instructed her to transfer the funds before he died. The court admitted bank records as business records, which showed the transfers occurred after Robert's death. Jill continued to access the account and transferred funds to herself without notifying the estate. Barbara intervened in the probate action, filing a third-party complaint against Jill for wrongful conversion and deceit. Jill counterclaimed, alleging unjust enrichment and seeking a constructive trust over the proceeds from the sale of their jointly owned home.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in admitting the bank records as business records. The court affirmed the District Court's finding that Jill converted the funds in Robert's account, as Barbara became the rightful owner upon Robert's death. However, the court found that Jill was entitled to her share of the proceeds from the sale of their jointly owned home, held in a resulting trust. The court denied Barbara's request for attorney fees and remanded the case for further proceedings consistent with its opinion. View "In re Estate of Brenden" on Justia Law

Susan McHugo Inouye sought damages and equitable remedies against Gregory McHugo, Nancy McHugo, and the estate of Patricia Bixby McHugo, alleging that Patricia breached a contract for mutual wills made with Susan’s father, John McHugo, under which Susan was a beneficiary. The trial court dismissed Susan’s claims, concluding that Patricia’s notice of intent to revoke her will during John’s life meant there was no detrimental reliance and thus no enforceable contract. Alternatively, the court found that John consented to rescission of the mutual-wills contract.The Superior Court, Windsor Unit, Civil Division, initially reviewed the case. The court found that John had notice of Patricia’s intention to change her will and did not alter his own estate plan in response. The court concluded that there was no detrimental reliance by John and that mutual consent was not required to revoke the contract. The court also suggested that John’s inaction indicated his consent to rescind the contract. Susan appealed the decision.The Vermont Supreme Court reviewed the case and concluded that the mutual-wills contract was enforceable on its own terms and that unilateral notice of intent to revoke was insufficient to rescind the contract. The court held that mutual consent was required to revoke the contract, as explicitly stated in the contract. The court found that the trial court’s conclusion that John consented to rescission was inadequately supported by the record, as mere inaction did not constitute consent. The Vermont Supreme Court reversed the trial court’s decision and remanded the case for further proceedings consistent with its opinion. View "Inouye v. Estate of McHugo" on Justia Law

In this case, Robert Z. Maigetter and Barbara J. Berot jointly owned a co-op apartment in Washington, D.C., which Berot's son, Alexis Kyriakopoulos, used. After Berot was diagnosed with terminal cancer, she and Maigetter executed parallel wills, with Berot expressing her wish for the co-op to pass to Kyriakopoulos. Berot passed away in May 2020, and Maigetter sought advice from their attorney, Sarah A. Eastburn, resulting in several email exchanges. Kyriakopoulos sued Maigetter to enforce an alleged contract to will the co-op to him, claiming Maigetter agreed to this arrangement before Berot's death.The United States District Court for the Eastern District of Pennsylvania reviewed the case and, after an in-camera review, ordered the production of twelve emails between Maigetter and Eastburn, finding them probative of Berot's intentions and subject to the testamentary exception to the attorney-client privilege. The District Court certified a narrow question for appeal regarding the scope of the testamentary exception, specifically whether it applies only to communications made by the deceased or also to communications made by others discussing the deceased's statements.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the District Court's application of the testamentary exception exceeded its traditional bounds. The Third Circuit held that the testamentary exception applies only to communications between the deceased client and their attorney, not to third-party communications made after the client's death. The court emphasized that the attorney-client privilege belongs to the client and can only be waived by the client or through an implied waiver in specific circumstances, which did not apply here. Consequently, the Third Circuit vacated the District Court's order compelling the production of the emails and remanded the case for further proceedings. View "Kyriakopoulos v. Maigetter" on Justia Law

Occidental Petroleum Corporation acquired Anadarko Petroleum Corporation in 2019, resulting in a trust holding a significant amount of Occidental stock. Wells Fargo, acting as trustee, agreed via email to sell the stock between January 6 and January 10, 2020. However, Wells Fargo failed to execute the sale until March 2020, by which time the stock's value had significantly decreased, causing a loss of over $30 million. Occidental sued Wells Fargo for breach of contract based on the email chain and the Trust Agreement.The United States District Court for the Southern District of Texas granted summary judgment in favor of Occidental, finding that Wells Fargo breached the Trust Agreement by failing to sell the stock as planned. The court also dismissed Wells Fargo’s counterclaim and affirmative defenses and awarded damages and attorney’s fees to Occidental.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the 2019 email chain did not constitute a contract due to lack of consideration. However, Wells Fargo was judicially estopped from arguing that the Trust Agreement was not a contract, as it had previously asserted that the relationship was contractual to dismiss Occidental’s fiduciary-duty claim. The court affirmed that Wells Fargo breached the Trust Agreement by failing to prudently manage the Trust’s assets.The Fifth Circuit also upheld the district court’s calculation of damages, rejecting Wells Fargo’s argument that reinvestment should have been considered. The court found that reinvestment was speculative and unsupported by the record. Additionally, the court affirmed the dismissal of Wells Fargo’s counterclaim and affirmative defenses, as Wells Fargo failed to show a genuine dispute of material fact. Finally, the court upheld the award of attorney’s fees, finding no basis for segregating fees based on Wells Fargo’s different capacities. The district court’s judgment was affirmed. View "Occidental Petroleum v. Wells Fargo" on Justia Law

The case involves a dispute over the sale of real property owned by the estate of Mark Engelhardt. Yvonne Engelhart, the personal representative of the estate, sent a notice letter to interested parties, including the Ebels and Tom Gross, outlining the bidding process for the property. The Ebels submitted bids that complied with the notice letter's requirements, while Gross submitted bids that did not meet the specified conditions. Despite this, the estate's attorney initially declared the Ebels the winning bidders but later accepted Gross's bids after he questioned the process.The District Court of McIntosh County initially dismissed the Ebels' claims, concluding the contracts were invalid due to the statute of frauds. The North Dakota Supreme Court reversed this decision, stating the statute of frauds was not properly raised. On remand, the district court declared the contracts between the Ebels and the estate valid and ordered specific performance. The court dismissed the Ebels' tortious interference claims against Gross, finding his actions justified.The North Dakota Supreme Court reviewed the case and affirmed the district court's decision. The court held that valid contracts were formed between the Ebels and the estate when the estate's attorney declared them the winning bidders. The court found that Gross's bids did not comply with the notice letter's requirements and that he had actual notice of the Ebels' winning bids, disqualifying him as a good-faith purchaser. The court also upheld the dismissal of the Ebels' tortious interference claims, concluding Gross's actions were reasonable and justified under the circumstances. View "Ebel v. Engelhart" on Justia Law

This case involves a dispute over the will of the late Donelson C. Glassie. The plaintiff, Marcia Sallum Glassie, is the testator’s former wife. She appealed from a Superior Court judgment in favor of the defendant, Paul Doucette, in his capacity as Executor of the Estate of Donelson C. Glassie. The Superior Court affirmed an order of the Newport Probate Court denying the plaintiff’s petition for leave to file a claim out of time against the estate. The denied claim would have alleged a breach of contract, based on the plaintiff’s contention that a key provision of the testator’s will violated the terms of the couple’s property-settlement agreement.The plaintiff and the testator were married in 1986, had three children, and were divorced in 1993. According to their property-settlement agreement (PSA), the testator was to execute a will that would not only treat his obligations under the PSA as “a claim against any assets in [his] [e]state” but also “specifically bequest to [plaintiff] an amount equal to said obligations.” A dispute soon unfolded over what the PSA required of the testator’s will.In 2017, the Supreme Court of Rhode Island vacated the Superior Court judgment on multiple grounds. Relevant to the present appeal, the court determined “that the disputed provision in the will is ambiguous” because it “does not clearly specify under what circumstances plaintiff is to receive the sum of $2,000,000 or the circumstances under which she is to receive such other amount necessary to satisfy all of [the testator’s] remaining obligations.” Because “a proper resolution of this matter require[d] factfinding and conclusions of law with respect to [the] testator’s intent,” the court remanded the case to the Superior Court.Back in Superior Court, the plaintiff sought to amend her complaint with a claim for breach of contract. The Superior Court denied plaintiff’s motion to amend her complaint, in part because she did not first submit the claim to the probate court, and also because the applicable statute of limitations had expired. The plaintiff thereafter filed a petition in the Newport Probate Court for leave to file a claim out of time and, after the court denied her petition, she appealed that denial to the Superior Court.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court, concluding that the plaintiff’s failure to timely present her claim for breach of contract was not due to excusable neglect and, therefore, her claim must be denied. View "Glassie v. Doucette" on Justia Law

The case revolves around a dispute over a family farm in Minnesota. Richard and Paulette Dunn entered into a contract for deed with their son, Rory, for the sale of their family farm. The contract stipulated that Rory could not sell, assign, or otherwise transfer his interest in the farm without the Dunns' written consent. However, Rory died two years later without a will, and his interest in the farm was transferred to his young son by intestate succession. Jeffrey Kuhn, the personal representative of Rory’s estate, intended to divide the property and sell a portion of the farm on the open market. The Dunns responded by cancelling the contract for deed, arguing that the intestate transfer of Rory’s interest to his son without their consent was a breach of the contract.The district court ruled in favor of the Dunns, stating that the intestate transfer of Rory’s interest in the farm violated the consent-to-transfer provision and materially breached the contract for deed. However, the court of appeals reversed this decision, concluding that the intestate transfer of Rory’s estate as a result of Rory’s inaction did not violate the consent-to-transfer provision.The Minnesota Supreme Court was asked to decide whether an intestate transfer of an interest in a family farm breaches a consent-to-transfer provision in a contract for deed. The court held that the intestate transfer of Rory’s interest in the farm violated the consent-to-transfer provision and that this violation was a material breach of the contract for deed. Therefore, the court reversed the decision of the court of appeals. View "Kuhn vs. Dunn" on Justia Law

The case revolves around a dispute over the estate of Neil Smeenk. Denise Schipke-Smeenk, Neil's wife, and Ryan Smeenk, Neil's son, are the parties involved. Denise and Neil had executed mutual and reciprocal wills in 2017, along with an agreement that neither would revoke or amend their wills without the other's written consent. However, after their relationship deteriorated, Neil executed a new will without Denise's consent, disinheriting her to the extent allowed under South Dakota law and naming his children as the primary beneficiaries. Neil passed away shortly after. Denise filed a petition for formal, unsupervised probate concerning the 2017 will, and Ryan filed a competing petition to probate the 2019 will.The circuit court determined that Neil's 2019 will was valid and should be admitted into probate. The court concluded that the couple's agreement did not render Neil's 2017 will irrevocable, though it may subject his estate to liability. Denise later filed a motion for approval of a creditor claim in which she proposed to distribute Neil's estate according to the terms of his 2017 will. The circuit court conducted a court trial regarding Denise’s claim, but ultimately denied Denise’s claim, stating that Denise did not demonstrate that the circumstances supported the equitable remedy of specific performance.In the Supreme Court of the State of South Dakota, Denise appealed the circuit court's decision. The Supreme Court affirmed the circuit court’s decision to deny Denise’s claim after a court trial. Denise then filed a motion for partial summary judgment relating to her breach of contract claim against the estate of her deceased husband, Neil Smeenk. She changed the type of relief she was requesting; she was now seeking money damages for the breach instead of the specific performance remedy she had pursued unsuccessfully in the previous case. However, the circuit court concluded that Denise was barred from litigating her breach of contract claim against Neil’s estate. Denise appealed this decision, but the Supreme Court affirmed the circuit court's decision, stating that Denise had a complete and fair opportunity to litigate her breach of contract claim in the prior proceeding. View "Estate Of Smeenk" on Justia Law

In the Supreme Court of New Hampshire, the case involved Gail C. Tremblay, the plaintiff, and the Estate of Donald D. Bald, the decedent, and Allan Bald, the defendants. Tremblay and Donald Bald were engaged and lived together for over ten years but never married. During their relationship, they executed several agreements stating that if they were living together at the time of Bald's death, Tremblay would receive certain properties. Upon Bald's death, Tremblay initiated legal action, arguing that the agreements were enforceable contracts. The defendants disagreed, asserting that the agreements lacked consideration, and the Superior Court sided with the defendants.Upon review, the Supreme Court of New Hampshire reversed the lower court's decision, concluding that the agreements are enforceable. The court stated that a valid enforceable contract requires an offer, acceptance, consideration, and a meeting of the minds. While the defendants argued that the agreements lacked consideration because the couple was already living together when the agreements were executed, the court disagreed. The court held that the plaintiff's continued cohabitation constituted a benefit to the decedent, thereby satisfying the requirement for consideration. Furthermore, the court stated that either party's ability to end the relationship prior to the decedent's death did not affect the enforceability of the agreements. As a result, the court reversed the lower court's ruling and remanded for further proceedings. View "Tremblay v. Bald" on Justia Law