Justia Contracts Opinion Summaries

Plaintiffs in these consolidated appeals brought claims under the Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., related to their mortgage transactions. The court held that to accomplish rescission within the meaning of section 1635(f), the obligor must file a rescission action in court. Because neither plaintiffs accomplished rescission in this way within three years of their respective transactions, their right to rescind expired and the district court correctly entered summary judgment on these claims. Further, plaintiffs were not entitled, as a matter of law, to money damages for the banks' refusal to rescind, although their claim was cognizable, where the violation - that each set of plaintiffs were given one, rather than two TILA disclosures - was not facially apparent on the loan documents as set forth in section 1641. View "Keiran, et al. v. Home Capital, Inc., et al." on Justia Law

Plaintiff, a manufacturer of various personal care, household, and organic products, filed an action seeking a declaratory judgment that it did not breach its contract with defendants. On remand from the court, the district court reentered summary judgment for plaintiff and dismissed defendants' equitable counterclaims. The court held that, regardless of whether the 1988 Agreement or the 2006 Agreement governed, changing the status of the Lambert Group from sales associate to manufacturer's representatives was not prohibited by either contract and there could not be a breach. The court rejected defendants' implied covenant argument on the merits and were not persuaded that plaintiff's actions breached the implied covenant of good faith and fair dealing; even if it was unclear which agreement controlled, summary judgment was still appropriate if plaintiff did not breach either agreement; and the court rejected defendants' counterclaims for relief under theories of quantum meruit, promissory estoppel, and unjust enrichment where equitable relief was unavailable in Minnesota where the rights of the parties were governed by a valid contract and where defendants have not identified any evidence suggesting an incomplete or confusing agreement regarding compensation. Accordingly, the court affirmed the judgment. View "Watkins Inc. v. Chilkoot Distributing, Inc., et al." on Justia Law

Plaintiff, injured on an oil and gas rig, filed suit against various third parties - including TESCO and TESCO employee Jeffrey Anderson - after recovering workers' compensation benefits from his employer, DeSoto. SWE was the owner/operator of the oil and gas well. The court concluded that the SWE contract did not establish that the common law duty of care Anderson owed plaintiff extended to preventing unforeseen injuries caused by DeSoto's failure to follow SWE's safety rules; Anderson and TESCO had no duty to foresee that injury to a DeSoto employee would occur because other DeSoto employees not under defendants' control had failed to exercise their duty of care; ordinary care did not require Anderson to foresee that his encouraging word would cause a DeSoto driller to do something he had not already decided, indeed, been ordered to do; and the amount of encouragement Anderson gave the DeSoto driller was insubstantial. Finally, the district court did not abuse its discretion in striking an expert report submitted by plaintiff and in denying the motion to amend. Accordingly, the court affirmed the judgment. View "Williams v. Chartis Casualty Co. et al." on Justia Law

Plaintiff, acting as trustee for certain farm property pursuant to a deed of trust, brought this interpleader action seeking a determination of rights to the sales proceeds from an auction of the farm. The court held that the district court properly denied CNH's motion for summary judgment where CNH did not have a valid contract to purchase the farm; CNH could not set aside the sale to Gittaway Ranch; CNH failed to offer any evidence that its attorney's fees were reasonable and necessary or incidental to the protection or improvement of the farm; and the district court did not abuse its discretion in awarding sanctions against defendants. View "Garden, Jr. v. Central Nebraska Housing Corp., et al." on Justia Law

InCompass filed suit against XO asserting a single claim of promissory estoppel based on a former XO employee's alleged oral promise to enter into a multi-year lease with InCompass. InCompass appealed the district court's grant of XO's motion to strike InCompass's jury trial demand. In light of InCompass's inconsistency as to the precise measure of damages that it sought, and in light of the undeniably equitable nature of the promissory estoppel claim as a whole, the court held that InCompass's claim was properly regarded as equitable rather than legal and, consequently, InCompass was not entitled to a jury trial on its claim of promissory estoppel. Accordingly, the court affirmed the judgment. View "InCompass IT, Inc., et al. v. XO Communications Servs., et al." on Justia Law

Plaintiff filed suit seeking interest on benefits she received under an Accidental Death and Dismemberment (ADD) insurance policy issued by Hartford. The parties disagreed on whether Tennessee law or Missouri law applied. Plaintiff did not dispute Hartford's argument that under Missouri law and the policy language, Hartford paid the benefit to her when it was payable. Accordingly, the court concluded that plaintiff was not entitled to interest under Missouri law. Assuming Tennessee law applied, the court relied on Performance Sys., Inc. v. First Am. Nat'l Bank, to conclude that the Tennessee Supreme Court would likely construe "due" in Tenn. Code Ann. 7-14-109(b) to mean the time of payment designated in the policy, not the date of loss. In this instance, Hartford paid the benefit to plaintiff within the time of payment designated in the policy and, therefore, plaintiff was not entitled to interest under subsection (b). Accordingly, the court affirmed the judgment. View "Williamson v. Hartford Life & Accident, etc." on Justia Law

Doe Run commenced a declaratory action seeking to enforce Lexington's contractual duty to defend Doe Run per its Commercial General Liability (CGL) policies in two underlying lawsuits (the Briley Lawsuit and the McSpadden Lawsuit). These underlying lawsuits sought damages arising out of Doe Run's operation of a five-hundred-acre waste pile (Leadwood Pile). The court concluded that the pollution exclusions in the CGL policies precluded a duty to defend Doe Run in the Briley Lawsuit. The court concluded, however, that the McSpadden Lawsuit included allegations and claims that were not unambiguously barred from coverage by the pollution exclusions in the policies. The McSpadden Lawsuit alleged that the distribution of toxic materials harmed plaintiffs, without specifying how that harm occurred. The McSpadden complaint also alleged that Doe Run caused bodily injury or property damage when it left the Leadwood Pile open and available for use by the public without posting warning signs. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Doe Run Resources Corp. v. Lexington Ins. Co." on Justia Law

Doe Run commenced a declaratory judgment action seeking to enforce Lexington's contractual duty to defend Doe Run per its Commercial General Liability (CGL) policies in an underlying lawsuit. The underlying lawsuit alleged environmental property damage resulting from Doe Run's mine and mill operations. The court affirmed the district court's conclusion that Lexington had no duty to defend because the policies' absolute pollution exclusions unambiguously barred coverage of all claims asserted in the underlying lawsuit. View "Doe Run Resources Corp. v. Lexington Ins. Co." on Justia Law

Affordable appealed the district court's grant of Fannie Mae's motion to dismiss, concluding that EFA had not acted as Fannie Mae's agent in originating the loan for a senior living complex that Affordable purchased and that the loan documents unambiguously authorized a prepayment penalty. The court affirmed the dismissal of Affordable's claims for negligent misrepresentation, breach of the covenant of good faith and fair dealing, and unjust enrichment. However, the court reversed the dismissal of Affordable's breach of contract claim where the agreement was ambiguous as to whether "condemnation award" included a sale in lieu of condemnation and remanded for further proceedings. View "Affordable Communities of MO v. Federal Nat'l. Mortgage Assoc." on Justia Law

This case involved the interpretation of two contractual provisions under Minnesota law: an indemnification clause in a contract between PDSI and Miller and an insurance contract between Harleysville and PDSI which extended insurance coverage to PDSI's indemnification of third parties for tort liability caused, in whole or in part, by PDSI or by those acting on its behalf. The court agreed with the district court's finding that a PDSI employee's suit fell squarely within the indemnity provision of the 1989 Agreement between PDSI and Miller. The court also agreed with the district court's interpretation of the insurance agreements as requiring Harleysville to cover Miller's settlement of the employee's claims. Further, the court concluded that the undisputed facts established as a matter of law that PDSI or those acting on its behalf at least partly caused the employee's bodily injury within the terms of the Harleysville policy. Accordingly, the court affirmed the judgment. View "Harleysville Ins. Co. v. Physical Distrib. Serv., et al" on Justia Law