Justia Contracts Opinion Summaries

Shirley Gregg Dean (Shirley) and Marion Casey Dean (Casey) married in 1978. Shirley died in 1999. At the time, Shirley’s daughters (the sisters) decided not to probate their mother’s estate, basing their decision on their belief that Shirley had an oral contract with Casey for him to provide for them in his will. After Casey died in 2010, the sisters sued Casey’s estate for breach of an oral contract between Casey and Shirley. The trial court granted judgment in favor of the sisters, concluding that they carried their burden of proving that there was an oral agreement between Casey and Shirley to leave one-third of Casey’s estate to Shirley’s children if Shirley predeceased Casey. The Supreme Court reversed the judgment of the trial court ruling that a contract existed between Shirley and Casey, holding that the record lacked clear and convincing evidence as to the terms of the agreement between Casey and Shirley. View "Dean v. Morris" on Justia Law

In February 2011, two years and four months after Plaintiff learned she had been disinherited by her mother, Plaintiff filed a complaint against financial advisor Bradley Lott for fraud and constructive fraud. A jury found that Lott had committed constructive fraud but that Plaintiff knew or should have known before February 2007 that the fraud occurred. Based on the jury’s findings, the district court dismissed the action, concluding that Plaintiff’s claims were barred by the statute of limitations. The Supreme Court reversed the judgment, holding (1) the evidence did not support a finding that Plaintiff could have discovered the fraud sooner, and (2) therefore, the district court erred by dismissing the case based on the statute of limitations. Remanded for a new trial. View "Erdelyi v. Lott" on Justia Law

In 1997, the Courtenay C. Davis Foundation and Amy Davis (together, “Davis Interests”) entered into an agreement with the University of Wyoming Foundation and the Colorado State University Research Foundation (together, “University Foundations”) in which the Davis Interests donated land and other interests to the University Foundations subject to the terms of the agreement. In 2011, the University Foundations decided to sell the gifted property and listed it for sale. In 2012, the Davis Interests filed an action against the University Foundations seeking to enjoin the sale of the property. The district court dismissed the complaint for lack of standing. The Supreme Court affirmed, holding that the district court did not err in concluding that the donation from the Davis Interests to the University Foundations was a gift, that the agreement did not create an implied trust, and that only the attorney general had standing to enforce the terms of a charitable gift. View "Courtenay C. & Lucy Patten Davis Found. v. Colo. State Univ. Research Found." on Justia Law

THI of New Mexico at Hobbs Center, LLC and THI of New Mexico, LLC (collectively THI) operate a nursing home in Hobbs, New Mexico. When Lillie Mae Patton's husband was admitted into the home, he entered into an arbitration agreement that required the parties to arbitrate any dispute arising out of his care at the home except claims relating to guardianship proceedings, collection or eviction actions by THI, or disputes of less than $2,500. After Mr. Patton died, Mrs. Patton sued THI for negligence and misrepresentation. THI then filed a complaint to compel arbitration of the claims. The district court initially ruled that the arbitration agreement was not unconscionable and ordered arbitration. Under New Mexico law a compulsory-arbitration provision in a contract may be unconscionable, and therefore unenforceable, if it applies only, or primarily, to claims that just one party to the contract is likely to bring. The question before the Tenth Circuit was whether the Federal Arbitration Act (FAA) preempted the state law for contracts governed by the FAA. The Court held that New Mexico law was preempted in this case and the arbitration clause should have been enforced. View "THI of New Mexico at Hobbs v. Patton" on Justia Law

In 2001, Appellant moved into Decedent’s home at Decedent’s request, where he lived and cared for Decedent until Decedent’s death in 2010. After Decedent’s death, Appellant filed a creditor’s claim against Decedent’s estate, seeking compensation for the care and services he provided. Defendants, the co-administrators of the estate, denied Appellant’s claim. Appellant subsequently brought an action against Defendants. The district court granted summary judgment to the estate. The Supreme Court affirmed, holding that the district court did not err in finding no question of material fact existed and that Appellant failed as a matter of law on his claims for implied-in-fact contract, promissory estoppel, and unjust enrichment. View "Symons v. Heaton" on Justia Law

After Mary Lou Fox died, Plaintiff, Mary Lou's daughter and the administratrix of Mary Lou's estate, sued Mary Lou's former husband, Robert Fox. Plaintiff alleged that Mary Lou jointly owned 960 acres of farmland with Robert, that Robert deprived Mary Lou of her ownership interest in the land, and that Plaintiff was thereby deprived of an inheritance from Mary Lou. The circuit court granted summary judgment to Robert, concluding that Mary Lou had no ownership interest in the 960 acres. The Supreme Court affirmed, holding that each cause of action brought by Plaintiff failed because Mary Lou had no claim to a right of ownership in the 960 acres and Plaintiff had no authority supporting her claims. View "Niesche v. Wilkinson" on Justia Law

After Plaintiff filed a complaint for divorce from Dean Miller, Plaintiff and Dean executed a property settlement agreement providing that Dean would maintain life insurance for the benefit of the parties' four minor children until they reached the age of majority. Dean subsequently executed a service request form listing his children as the beneficiaries of his life insurance policy and instructing that beneficial interests be paid to and managed by Kristin Saunders as custodial trustee for the benefit of his minor children. After Dean died, funds from his life insurance policy were distributed to Saunders. Plaintiff filed a complaint seeking declaratory and injunctive relief asking the superior court to declare that Dean's four children were the sole beneficiaries of his life insurance policy. The court granted Defendants' motion for summary judgment, finding that Dean created a valid custodial trust pursuant to the Rhode Island Uniform Custodial Trust Act (RIUCTA) and that the trust was not inconsistent with Dean's obligations under the property settlement agreement. The Supreme Court affirmed, holding (1) Dean created a custodial trust pursuant to RIUCTA; and (2) Dean did not violate the property settlement agreement by designating Saunders as custodial trustee on the service request form. View "Miller v. Saunders" on Justia Law

Decedent was a resident of Searcy Healthcare Center (SHC) from January 7 to January 29. On January 8, Decedent executed a written arbitration agreement with SHC that was binding on Decedent's children, personal representatives, and administrators of Decedent's estate. Decedent died on February 12. The next year, Appellee filed a nursing-home-malpractice action against SHC as administrator of Decedent's estate and on behalf of the statutory wrongful-death beneficiaries. The circuit court denied SHC's motion to compel arbitration against the wrongful-death beneficiaries, concluding that Decedent had not extinguished the substantive rights of the wrongful-death beneficiaries by signing the arbitration agreement. The Supreme Court reversed, holding that the circuit court erred as a matter of law in finding that the wrongful-death beneficiaries were not bound by the arbitration agreement executed by Decedent. Remanded. View "Searcy Healthcare Ctr., LLC v. Murphy" on Justia Law

The Probate Court appointed Theodore Ballard's niece, Leala Bell, as Ballard's guardian. Bell signed a promissory note to a mortgage as a "borrower"; she did not expressly indicate that she was signing as Ballard's guardian or that her signature indicated only her "approval" of Ballard's action. The loan was secured by a mortgage on Ballard's real property. The mortgage deed granted and conveyed Ballard's property to CitiFinancial, including the power to sell the property. Ballard signed the mortgage deed but Bell did not. There was no showing that the probate court licensed the mortgage. CitiFinancial alleged that Ballard had failed to make the payments called for under the note and mortgage, and therefore breached these agreements. Ballard moved for summary judgment, arguing in relevant part that he lacked the legal capacity to execute a mortgage deed and promissory note while he was under guardianship. Upon review, the Supreme Court found that Ballard's argument relied on the notion that Bell participated in the transaction with CitiFinancial, subjected herself to personal liability as a cosigner of the note, signed the settlement statement as well as the promissory note, but did not actually approve Ballard's signing of the note. Although the mortgage deed purportedly executed by Ballard and the promissory note secured by that deed were executed as part of the same overall transaction, the two documents created distinct legal obligations. The Supreme Court concluded that the trial court erred in analyzing the note and mortgage as if they were one and the same, both subject to the requirement of probate court approval. Therefore the Court reversed the award of summary judgment to Ballard on CitiFinancial's claim on the promissory note and remanded the case back to the trial court for further proceedings on that claim. View "CitiFinancial, Inc. v. Balch" on Justia Law

After John Irvine died, the proceeds from three of his investment accounts were paid to his estate. John's mother, Va Va, sought a declaratory judgment that she was the sole beneficiary of all three accounts. John's stepson, Michael, opposed the action. Both Va Va and Michael filed summary judgment motions. Va Va argued that John intended to benefit his estate under the laws of intestacy, not under the terms of his 1983 will, which included Michael as a beneficiary, and that John intended for her to be the contingent beneficiary for all three accounts. To support her contention, Va Va offered testimony from John's financial planner, who testified that he erroneously believed that John did not have a will when he executed beneficiary designation forms for a number of accounts. Va Va argued that the written contracts should be reformed for mutual mistake. The district court concluded that Michael was entitled to summary judgment under the contract terms and that no legal basis existed to require reformation of the contracts. The Supreme Court affirmed, holding that the district court correctly determined that (1) the contracts could not be reformed; and (2) proceeds from John's investment accounts were properly paid to his estate. View "Estate of Irvine v. Oaas" on Justia Law