Justia Contracts Opinion Summaries

Darian McKinney, a health and physical education teacher, was employed by the District of Columbia Public Schools (DCPS) for four years. During his tenure, he was investigated for sexual harassment, leading to a grievance he filed against DCPS. Both disputes were resolved through a Settlement Agreement, under which McKinney resigned but was allowed to reapply for teaching positions. However, when he reapplied, DCPS blocked his return, citing a failed background check.McKinney sued the District of Columbia, alleging that DCPS breached the Settlement Agreement by not fairly considering his employment applications and deprived him of property and liberty without due process. The United States District Court for the District of Columbia dismissed his complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Settlement Agreement did not obligate DCPS to fairly consider McKinney’s applications, only to allow him to apply. The court found no basis in the contract’s language or law for McKinney’s demand for fair consideration. Additionally, the court ruled that McKinney did not have a constitutionally protected property interest in his original job, the contingent job offers, or his eligibility for DCPS positions. The court also found that McKinney’s claim of deprivation of liberty without due process was forfeited as it was not raised in the lower court.The court affirmed the district court’s dismissal of McKinney’s complaint. View "Darian McKinney v. DC" on Justia Law

Michigan Electric Transmission Company (METC) owns a high-voltage transmission line with Michigan Public Power Agency (MPPA) and Wolverine Power Supply Cooperative. The case concerns the ownership of new transmission facilities, or "network upgrades," connecting a new solar generation park to the transmission line. METC claims exclusive ownership based on existing agreements, while MPPA and Wolverine disagree.The Federal Energy Regulatory Commission (FERC) reviewed the case and found that no agreement conclusively determined ownership rights. FERC declined to decide the ownership question, leading METC to petition for review.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court agreed with FERC's interpretation that the relevant agreements did not grant METC exclusive ownership of the network upgrades. The court found that the Styx-Murphy line qualifies as a "system" under the Transmission Owners Agreement (TOA), and since METC is not the sole owner, it cannot claim exclusive ownership. The court also found that the Styx-Murphy Agreements did not preclude MPPA and Wolverine from owning network upgrades.The court denied METC's petitions for review, upholding FERC's decision. View "Michigan Electric Transmission Company, LLC v. FERC" on Justia Law

In 2013, the Metropolitan Municipality of Lima (Lima) and Rutas de Lima S.A.C. (Rutas) entered into a Concession Contract for the construction and operation of urban roads in Lima, Peru. Rutas agreed to finance and manage the project in exchange for toll revenue, while Lima was responsible for preliminary infrastructure activities. Subsequent agreements transferred these preliminary responsibilities to Rutas in exchange for toll rate increases. Social protests erupted in response to these increases, leading Lima to close a toll unit and refuse further rate hikes. Rutas initiated two international arbitrations, claiming Lima breached the contract. Lima argued the contract was void due to bribery by Rutas’s parent company, Odebrecht S.A.The District Court for the District of Columbia reviewed the case after two arbitration tribunals ruled in favor of Rutas, finding insufficient evidence of corruption linked to the Concession Contract. Lima sought to vacate the arbitration awards, citing violations of U.S. public policy against corruption, fraud by Rutas in discovery, and misconduct by the second tribunal in excluding evidence. The District Court denied Lima’s petitions and confirmed the awards, concluding that Lima failed to prove the contract was obtained through bribery and that any alleged discovery misconduct did not prejudice Lima’s case.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court’s judgment. The court held that the arbitration tribunals’ findings were supported by the record and that there was no sufficient evidence linking Odebrecht’s bribes to the Concession Contract. The court also found no merit in Lima’s claims of discovery fraud and tribunal misconduct, noting that Lima suffered no prejudice from the exclusion of evidence. The court concluded that enforcing the arbitration awards did not violate U.S. public policy. View "Metropolitan Municipality of Lima v. Rutas De Lima S.A.C." on Justia Law

In early 2020, Robert Goodrich liquidated his stock portfolio due to concerns about the financial market's reaction to the COVID-19 pandemic, resulting in significant financial losses. Goodrich had an investment account with U.S. Trust Bank of America Private Wealth Management, managed by Matthew Lettinga. Despite advice from Lettinga to avoid liquidation, Goodrich insisted on selling his portfolio. Goodrich later sued Lettinga and Bank of America, claiming gross negligence, breach of fiduciary duty, and violations of the D.C. Securities Act, arguing that he was not adequately informed of the risks involved in liquidating his portfolio.The U.S. District Court for the District of Columbia dismissed Goodrich's claims of gross negligence and violations of the D.C. Securities Act, finding them implausibly pleaded. The court allowed the breach of fiduciary duty claim to proceed but later granted summary judgment in favor of the defendants, concluding that Goodrich had explicitly instructed the sale of his portfolio, which precluded liability under the terms of the investment agreement.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the District Court's decisions. The appellate court held that the investment agreement's exculpatory clauses were enforceable and that Goodrich's explicit instruction to liquidate his portfolio shielded the defendants from liability. The court also agreed that Goodrich failed to plausibly allege scienter, a necessary element for his claims under the D.C. Securities Act, and found no abuse of discretion in the District Court's limitation of discovery to the dispositive issue of whether Goodrich instructed the sale. View "Goodrich v. Bank of America N.A." on Justia Law

Chenari, a third-year George Washington University medical student, took a test published by the National Board of Medical Examiners. Before the exam, the proctor read aloud the instructions from NBME’s official manual, including that students must complete the exam in two and a half hours and that “[n]o additional time [would] be allowed for transferring answers” to the answer sheet. Chenari also received a copy of “Exam Guidelines,” containing a similar warning. When the proctor called time, Chenari discovered that he had failed to transfer 20-30 answers to his answer sheet, “panicked,” and continued to transfer answers. The proctor requested that he stop; he continued. When the proctor tried to take the exam, Chenari put his hand over it and continued entering answers, taking an additional 90-120 seconds. The proctor and another student reported Chenari. Pursuant to University procedures, an Honor Code Council subcommittee investigated and recommended dismissal for academic dishonesty. The Medical Student Evaluation Committee unanimously recommended Chenari’s dismissal. The Medical School Dean met with Chenari and upheld that recommendation. Chenari unsuccessfully appealed to the Provost, arguing that his conduct lacked “an element of deceit” like “cheat[ing]” or “l[ying].” The D.C. Circuit affirmed dismissal of Chenari’s suit, which alleged breach of contract and discrimination based on his disability, Attention Deficit Hyperactivity Disorder (ADHD), 29 U.S.C. 794(a), and 42 U.S.C. 12132. The court noted that Chenari never sought accommodation of his claimed disability under the school’s established procedures. View "Chenari v. George Washington University" on Justia Law

GSS appealed the district court’s dismissal of its second attempt to confirm a $44 million arbitral award entered against the Port Authority for breach of a construction contract. GSS first tried to confirm the award, but the district court found that it had no personal jurisdiction over the Port Authority. Then GSS filed its second petition, also naming the Republic of Liberia, which owns the Port Authority, as respondents. The district court again dismissed GSS’s petition, finding that issue preclusion barred relitigating its personal jurisdiction over the Port Authority and that GSS failed to demonstrate that Liberia was liable for the Port Authority’s alleged breach. The court affirmed the district court's dismissal of the claims against Liberia for lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1330 et seq.; affirmed the district court's dismissal of GSS's petition against the Port Authority on sovereign immunities grounds; and concluded that the district court did not abuse its discretion by dismissing GSS's petition before allowing jurisdictional discovery. View "GSS Group Ltd. v. Republic of Liberia" on Justia Law