Justia Contracts Opinion Summaries

Brian Harnett worked as an account executive and salesman for Corporate Technologies, Inc. (CTI), which provided Harnett information technology solutions to sophisticated customers. When Harnett was hired, he signed an agreement that contained non-solicitation and non-disclosure provisions. Harnett later left CTI and began working for OnX USA LLC (OnX), where he participated in sales-related communications and activities with certain of his former CTI customers on behalf of OnX. CTI sued Harnett, alleging breach of contract and tortious interference with CTI's contractual rights and advantageous relationships. CTI sought a preliminary injunction restraining Harnett from doing business with certain customers, which the district court granted. The First Circuit Court of Appeals affirmed the issuance of the preliminary injunction, holding that the district court's conclusion that Harnett likely engaged in solicitation in violation of the agreement was reasonable, and therefore, the court did not err in granting injunctive relief. View "Corporate Techs., Inc. v. Harnett" on Justia Law

This case arose from a Hampton Inn & Suites renovation and construction in Rhode Island. Stonestreet Construction, as the construction manager and general contractor, entered into a construction contract with Weybosset Hotel. Because of cost overruns and other delays, Allstate Interiors & Exteriors, one of the subcontractors on the project, filed a complaint against Stonestreet. Stonestreet counterclaimed against Allstate and brought a third-party complaint against Weybosset, bringing several state law causes of action arising from the construction project. After a trial on Stonestreet's third-party complaint against Weybosset, the district court ruled in favor of Stonestreet on its breach of contract claim and awarded damages in the amount of $571,595. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) exercising supplemental jurisdiction following Allstate and Stonestreet's partial settlement; (2) interpreting the construction contract for the purpose of calculating damages; and (3) denying Weybosset's discovery motion regarding supplemental expert reports. View "Stonestreet Constr., LLC v. Weybosset Hotel, LLC" on Justia Law

Plaintiff borrowed money from Countrywide Financial and secured the loan with a mortgage on real property. The recorded mortgage was assigned to the Bank of New York Mellon (BONY), which also held the note on Plaintiff's property. When Plaintiff was unable to make payments on the mortgage, BONY instituted judicial foreclosure proceedings. Plaintiff filed suit to enjoin the foreclosure, arguing that (1) the description of his property in the mortgage did not satisfy New Hampshire's statute of frauds, and (2) Countrywide's unilateral addition of a more precise description of the property to the copy of the mortgage was an act of fraud that should bar BONY from foreclosing. The district court rejected both of Plaintiff's arguments. The First Circuit Court of Appeals affirmed, holding (1) the description of the property, in light of the surrounding circumstances, was not so imprecise as to be unenforceable under the New Hampshire statute of frauds; and (2) because the description of the property attached to the mortgage was correct, Countrywide's unilateral addition of a more precise description of the property was not fraudulent. View "French v. Bank of New York Mellon" on Justia Law

Plaintiff, a Massachusetts corporation engaged in international asset recovery operations, filed a complaint against Defendants, the Republic of Ukraine and some of its agents and instrumentalities, for, inter alia, breach of contract after Plaintiff performed asset recovery work for which Defendants allegedly did not compensate Plaintiff. Defendants filed a motion to dismiss on the grounds that they were entitled to immunity under the Foreign Sovereign Immunities Act (FSIA). The district court denied the motion in regard to the breach of contract claim, concluding that jurisdiction could be asserted over that claim under the commercial activity exception to the FSIA. The First Circuit Court of Appeals affirmed the district court's exercise of jurisdiction over Plaintiff's breach of contract claim, holding that Defendants' transactions with Plaintiff constituted commercial activity exempt from immunity under FSIA. View "Universal Trading & Inv. Co. v. Bureau for Representing Ukrainian Interests" on Justia Law

About thirty years ago, the Municipality of Mayaguez and Corporacion Para el Desarrollo del Oeste (CPDO), a local development corporation, executed a contract under which Mayaguez ceded parcels of land to CPDO with the understanding that the land would be used for a project to be developed in accordance with the Department of Housing and Urban Development's (HUD) Community Development Block Grant program guidelines and regulations. After the relationship between the parties soured, Mayaguez filed this complaint against CPDO, alleging that CPDO violated several HUD regulations, thus breaching its contract. The district court ruled in favor of CPDO and dismissed Mayaguez's claims without prejudice. The First Circuit Court of Appeals vacated the district court's judgment, holding that Mayaguez's commonwealth law claim did not "arise under" federal law within the meaning of 28 U.S.C. 1331. Remanded with instructions to dismiss Mayaguez's claim without prejudice for want of subject matter jurisdiction. View "Municipality of Mayaguez v. Corporacion Para El Desarrollo Del Oeste, Inc." on Justia Law

The Knowles owned rental property in Clinton, Massachusetts that was mortgaged with Fidelity Co-operative Bank (Fidelity) and insured by Nova Casualty Company (Nova). In 2008, a tropical storm brought heavy rain that caused substantial damage to the interior of the Knowles' building. The Town of Clinton ordered the building to be closed. Because the Knowles could not afford to make repairs to the building, it remained vacant. The Knowles submitted a claim for reimbursement for the water damage with Nova, which denied the claim. The building was later vandalized, causing further damage. Nova also refused coverage on this damage. The Knowles subsequently defaulted on their mortgage. In 2010, Fidelity, individually and as assignee of the Knowles, filed a complaint against Nova seeking a declaration that the physical losses suffered by the property and the loss of business income to the Knowles was covered by their all-risk insurance policy. The district court granted summary judgment for Nova. The First Circuit Court of Appeals reversed, holding that the water damage was covered under the policy because the policy's coverage extended to both damage "caused by" or "resulting from" rain as well as damage resulting from the entry of "surface water." Remanded. View "Fidelity Coop. Bank v. Nova Cas. Co." on Justia Law

Plaintiffs, current and former employees of Boston Medical Center (BMC), brought this wage-and-hour action against BMC, BMC's former president and COE, and BMC's former senior human resources officer, alleging that Defendants deprived them of their wages through the use of timekeeping policies and employment practices that required them to put in extra work time in addition to their regularly scheduled work shifts and to work through their meal and rest periods. Plaintiffs asserted causes of action under the Fair Labor Standards Act (FLSA) and Massachusetts common law. The federal district court granted Defendants' motion to dismiss in its entirety. The First Circuit Court of Appeals (1) vacated the dismissal of the FLSA claim against BMC and its former CEO, the contract claims, and the money had and received, unjust enrichment, and conversion claims; (2) vacated the district court's order striking the class and collective action allegations; and (3) otherwise affirmed. Remanded. View "Manning v. Boston Med. Ctr. Corp." on Justia Law

Plaintiff terminated Defendant from employment. Thereafter, Defendant began arbitration proceedings seeking severance compensation he felt was contractually due. After arbitration hearings had commenced, the hearings were postponed for two months due to a medical situation afflicting Plaintiff's counsel. During the recess, Plaintiff formally requested pre-hearing and hearing third-party subpoenas directed at Defendant's current employer. The tribunal denied the issuance of the subpoenas. After the arbitration hearings resumed, the tribunal found Defendant was entitled to compensation pursuant to the terms of his employment agreement dealing with his termination without cause. The tribunal also found Defendant was entitled to pre-award interest. Plaintiff subsequently sought vacatur of the award, which the trial court denied. The First Circuit Court of Appeals affirmed, holding (1) the arbitration tribunal did not engage in misconduct by denying the issuance of the pre-hearing and hearing subpoenas; and (2) the tribunal did not exceed its authority in awarding pre-award interest to Defendant. View "Doral Fin. Corp. v. Garcia-Velez" on Justia Law

Plaintiff sought to open a Victoria's Secret franchise and sought assistance from Richard Domingo, an employee of Rekomdiv International. At the recommendation of Domingo, Plaintiff retained the law firm of Venable, LLP to assist him in establishing a business relationship with Victoria's Secret. Plaintiff paid Venable a $400,000 retainer fee, and paid $225,000 to Rekomdiv. Plaintiff later discovered Victoria's Secret franchise was not available. Plaintiff sued Rekomdiv and Domingo for breach of contract and dolo. The jury found in favor of Plaintiff and assessed damages in the amount of $625,000. In the meantime, Plaintiff sued Venable, and the parties settled. The court later found that it could not offset the damages award in the Rekomdiv suit by the Venable settlement amount. While their appeal was pending in this matter, Rekomdiv and Domingo filed a legal malpractice suit against Lamboy, their trial counsel. The district court dismissed the complaint against Lamboy. The First Circuit Court of Appeals (1) affirmed the district court's denial of offset of the damages award, as offset was not required; and (2) affirmed the court's dismissal of the legal malpractice suit, holding that the allegations in the complaint failed to establish the causation element necessary to make out a plausible legal malpractice claim. View "Portugues-Santana v. Rekomdiv Int'l, Inc." on Justia Law

Defendant and his company (Defendants) borrowed money from Trust by executing promissory notes in favor of Trust. One note said it was governed by Massachusetts law, and the others said they were governed by New York law. The Trust's trustees (Plaintiffs) subsequently sued Defendants in New York state court for breach of contract. The New York trial court eventually granted Defendants' motion to dismiss based on the expiration of the New York statute of limitations. Plaintiffs subsequently sued Defendant in Massachusetts federal court to recover on the note controlled by Massachusetts law. Although Plaintiffs filed suit within the Massachusetts statute of limitations, the district judge concluded that the dismissal of the New York lawsuit barred Plaintiffs' current claim because the dismissal was on the merits and claim preclusive. The First Circuit Court of Appeals affirmed, holding that the limitations dismissal under New York law was a judgment on the merits, and thus, the current claim was barred. View "Newman v. Krintzman" on Justia Law