Justia Contracts Opinion Summaries

Appellee sued appellant for breach of contract stemming from an agreement between the parties under which appellant would produce, package, and deliver a rice milk product to appellee. At issue was whether the district court erred in denying appellant's motion for new trial because the court failed to give jury instructions regarding the proper standard of breach of an installment contract and the law pertaining to delegation of a contract. Also at issue was whether the district court erred in denying appellant's motion for judgment as a matter of law because appellee failed to prove a breach of the entire installment contract. The court held that the jury instructions, taken together, fairly and adequately submitted the breach of contract issue to the jury and that the district court properly declined to instruct the jury on the issue of delegation because the issue was irrelevant to the case presented to the jury. The court also held that appellant failed to preserve the issue of whether there was insufficient evidence to prove a breach of the entire installment contract and therefore, the court had no power to review this issue. Accordingly, the judgment of the district court was affirmed.

Saint Francis Medical Center ("St. Francis") brought a class action suit against C.R. Bard, Inc. ("Bard"), a supplier of medical supplies, alleging that Bard's contracts with Group Purchasing Organizations violated the Sherman Act, 15 U.S.C. 1, 2, section 3 of the Clayton Act, 15 U.S.C. 14, and Missouri antitrust law, Mo. Rev. Stat. 416.121.1. At issue was whether the district court properly granted summary judgment for Bard. The court held that, based on the precedent of Concord Boat Corp. v. Brunswick Corp., and specifically Saint Francis's failure to identify a relevant submarket, the judgment of the district court granting summary judgment to Bard was affirmed.

Owatonna Clinic-Mayo Health System ("Clinic") sued its insurer, Medical Protective Company ("Medical Protective"), claiming that the company had breached its obligation to defend and indemnify the Clinic in a medical malpractice suit that had resulted in a judgment against it. At issue was whether the district court erred in ruling as a matter of law that the Clinic's notice to Medical Protective, of a potential claim against it, conformed to the insurance policy requirements and whether the Clinic's belief that it was at risk was objectively reasonable. Also at issue was whether the Clinic was entitled to pre-judgment interest. The court affirmed the judgment and held that the Clinic was deemed to have filed a timely notice with Medical Protective where the information that Medical Protective received would obviously alert a reasonable insurer to the likelihood of possible allegations of liability on the Clinic's part. The court also held that Medical Protective's challenge to the district court's finding, that the Clinic's belief that it was at risk was objectively reasonable, was meritless where the quoted policy language set an exceedingly low bar. The court further held that the district court did not err in awarding pre-judgment interest under Minn. Stat. 60A.0811, subd. 2(a) where the statute was unambiguous; and, in the alternative, if the statute was ambiguous, the court construed it against the insurer.