Justia Contracts Opinion Summaries

BCC Partners, LLC ("BCC") contracted with Ben F. Blanton Construction, Inc. ("Blanton") to build an apartment complex in Creve Coeur, Missouri. Blanton obtained an insurance policy from Travelers Property Casualty Company of America ("Travelers"), naming Blanton as the "Named Insured" and BCC as an "Additional Named Insured." A retaining wall failure during construction led to damage and delays, resulting in multiple insurance claims. Travelers paid $1.3 million into an escrow account, which was divided among claimants. BCC later sought coverage for loss of rental income and soft costs due to the delays, but Travelers denied the claim after an initial advance payment of $200,000.The United States District Court for the Eastern District of Missouri granted summary judgment to Travelers, concluding that BCC was not entitled to the demanded payments under the Policy. BCC appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that under the plain meaning of the Policy, only a "Named Insured" is covered for losses of rental income and soft costs. BCC, as an "Additional Named Insured," did not qualify for such coverage. The court found that the Policy's language was clear and unambiguous, and BCC's arguments to the contrary were unavailing. Consequently, the court affirmed the district court's judgment, ruling that Travelers did not breach the Policy and that BCC's claim for vexatious refusal to pay also failed. View "BCC Partners, LLC v. Travelers Property Casualty Co. of America" on Justia Law

Brett Jens resigned from his position at Wilbur-Ellis Company, LLC, and subsequently joined a competitor, J.R. Simplot Company. Wilbur-Ellis filed a lawsuit against Jens and Simplot, seeking a preliminary injunction to enforce restrictive covenants in Jens’s employment agreement and to prevent Simplot’s alleged tortious interference with the agreement. The district court denied the motion for a preliminary injunction, concluding that the restrictive covenants were no longer enforceable.The United States District Court for the District of South Dakota reviewed the case and determined that Wilbur-Ellis was unlikely to succeed on the merits of its breach of contract claim against Jens. The court found that the restrictive covenants in Jens’s employment agreement did not survive past the agreement’s expiration date of February 28, 2010. Wilbur-Ellis appealed the denial of the preliminary injunction, arguing that the restrictive covenants were intended to begin when Jens’s employment ended. Simplot cross-appealed, contending that Wilbur-Ellis could not enforce the restrictive covenants because the employer in the agreement was Wilbur-Ellis Air, LLC, not Wilbur-Ellis Company, LLC.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court affirmed the district court’s denial of the preliminary injunction, agreeing that the restrictive covenants did not survive the expiration of the employment agreement. The court emphasized that the agreement did not contain a survival clause or any language indicating that the restrictive covenants were intended to extend beyond the termination of the agreement. Consequently, the court concluded that Wilbur-Ellis was unlikely to succeed on the merits, which is the most significant factor in determining whether to issue a preliminary injunction. View "Wilbur-Ellis Company LLC v. Jens" on Justia Law

The case involves Billings County and its commissioners, who appealed a district court's decision to grant a preliminary injunction preventing them from entering the property of Sandra Short, David Short, Donald Short, and Sarah Sarbacker. The dispute centers on the County's attempt to use eminent domain to construct a bridge over the Little Missouri River, known as the Little Missouri River Crossing (LMRC). The Shorts had previously settled a lawsuit with the County in 2021, where the County agreed not to pursue eminent domain for the LMRC project. Despite this, a newly elected Board of Commissioners decided to proceed with the project in 2023, leading the Shorts to file a new lawsuit.The United States District Court for the District of North Dakota granted a preliminary injunction in favor of the Shorts, finding that they were likely to succeed on their breach-of-contract claim based on the Settlement Agreement. The court refrained from deciding on the validity of the Settlement Agreement, leaving that issue for the state court to address. The district court also stayed its proceedings, pending the outcome of the state court case, and denied the County's motion to dismiss without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case and vacated the preliminary injunction. The appellate court held that the County could not lawfully contract away its power of eminent domain, as it is an essential attribute of sovereignty. The court concluded that the Settlement Agreement was contrary to law and that the Shorts were not likely to succeed on their breach-of-contract claim. The case was remanded for further proceedings consistent with this opinion. View "Short v. Billings County" on Justia Law

An egg farm owned by Rembrandt Enterprises, Inc. experienced a collapse of its poultry cage system in 2020, resulting in significant damage and the death of a farm worker. Rembrandt had contracted with Tecno Poultry Equipment, SpA in 2006 to design and manufacture the cage system, which included a provision for Tecno to supervise its installation. The installation was completed in 2007. Rembrandt sued Tecno in 2021, alleging strict products liability, breach of implied warranties, and negligence. The district court allowed the negligence claim to proceed to trial, where a jury found that Tecno did not breach its duty to supervise the installation.The United States District Court for the Northern District of Iowa granted summary judgment for Tecno on the strict products liability and breach of implied warranties claims. At trial, the jury heard conflicting expert testimony regarding the cause of the collapse. Rembrandt's expert attributed the collapse to missing screws and misplaced bolts, while Tecno's experts blamed improper manure disposal by Rembrandt. The jury ultimately sided with Tecno, and the district court entered judgment in favor of Tecno.The United States Court of Appeals for the Eighth Circuit reviewed the case. Rembrandt argued that the district court erred in denying its motions for judgment as a matter of law and in excluding a screenshot of Tecno's website. The appellate court held that Rembrandt failed to preserve its challenge to the sufficiency of the evidence by not renewing its motion under Rule 50(b) after the jury verdict. The court also found that the district court did not abuse its discretion in excluding the website screenshot, as it was not relevant to the 2006 contract. The Eighth Circuit affirmed the district court's judgment. View "Rembrandt Enterprises, Inc. v. Tecno Poultry Equipment, SpA" on Justia Law

InfoDeli, LLC and Breht C. Burri (collectively, InfoDeli) brought a lawsuit against Western Robidoux, Inc. (WRI), Engage Mobile Solutions, LLC, and other defendants, including members of the Burri family and several companies. InfoDeli alleged copyright infringement, tortious interference, and violations of the Missouri Computer Tampering Act (MCTA). The dispute arose from a joint venture between InfoDeli and WRI, where InfoDeli created webstores for clients, and WRI provided printing and fulfillment services. The relationship deteriorated when WRI hired Engage to replace InfoDeli's webstores, leading to the lawsuit.The United States District Court for the Western District of Missouri granted summary judgment to the defendants on the copyright infringement claim, dismissed or tried the remaining claims before a jury, which found in favor of the defendants. The district court also granted in part and denied in part InfoDeli's sanctions motion and awarded attorney’s fees and costs to the defendants. InfoDeli appealed these decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's grant of summary judgment on the copyright infringement claim, finding that InfoDeli failed to show that the nonliteral elements of its webstores were protected by copyright. The court also upheld the district court's denial of InfoDeli's motion for summary judgment on CEVA's conversion counterclaim, finding it was timely under Missouri law. Additionally, the court affirmed the district court's denial of InfoDeli's posttrial motions for judgment as a matter of law and a new trial as untimely.The Eighth Circuit also reviewed the sanctions imposed by the district court and found no abuse of discretion in the amount awarded or the decision not to impose additional sanctions under Rule 37(e). Finally, the court upheld the award of attorney’s fees and costs to the defendants, finding that the district court did not abuse its discretion in its assessment. The court affirmed the district court's decisions in all respects. View "InfoDeli, LLC v. Western Robidoux, Inc." on Justia Law

Plaintiffs, E&I Global Energy Services, Inc. and E&C Global, LLC, sued Liberty Mutual Insurance Company for breach of contract and tort claims related to a construction project. The United States, through the Western Area Power Administration (WAPA), contracted with Isolux to build a substation, and Liberty issued performance and payment bonds for Isolux. After Isolux was terminated, Liberty hired E&C as the completion contractor, but E&I performed the work. Plaintiffs claimed Liberty failed to pay for the work completed.The United States District Court for the District of South Dakota granted summary judgment for Liberty on the unjust enrichment claim and ruled in Liberty's favor on all other claims after a bench trial. The court denied Plaintiffs' untimely request for a jury trial, excluded an expert witness report filed after the deadline, found no evidence of an assignment of rights between E&C and E&I, and ruled against Plaintiffs on their fraud, deceit, and negligent misrepresentation claims.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the jury trial request, as Plaintiffs failed to timely file the motion and did not justify the delay. The exclusion of the expert report was also upheld, as the district court properly applied the relevant factors and found the late report was neither substantially justified nor harmless. The court affirmed the district court's finding that there was no valid assignment of rights from E&C to E&I, meaning Liberty's promise to pay was to E&C, not E&I. The court also upheld the findings that Liberty did not have the intent to deceive or induce reliance, and that Bruce did not reasonably rely on Mattingly's statements. Finally, the court declined to address the unjust enrichment claim as Plaintiffs did not raise the argument below. The Eighth Circuit affirmed the district court's rulings in their entirety. View "E&I Global Energy Services v. Liberty Mutual Insurance Co." on Justia Law

Cedar Hills Investment Co., L.L.C. leased part of the ground under the Battlefield Mall in Springfield, Missouri, to Battlefield Mall LLC. Cedar Hills suspected that Battlefield was improperly deducting certain costs from revenue-sharing payments owed under the lease. Cedar Hills sued Battlefield, and the district court found that Battlefield had improperly deducted capital expenditures and some administrative costs from shared revenue. The court approved the deduction of security costs and other administrative costs but held that Battlefield failed to state charges to subtenants for deducted costs separately as required by the lease. Cedar Hills was awarded approximately $3.5 million in damages.The United States District Court for the Western District of Missouri held a bench trial and ruled in favor of Cedar Hills on several points, including the improper deduction of capital expenditures and the failure to separately state charges. However, the court also found that Battlefield's deduction of security costs was permissible.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's findings regarding the improper deduction of capital expenditures and the failure to separately state charges. However, the appellate court found that the district court misidentified which administrative costs were deductible and miscalculated Cedar Hills's damages. The Eighth Circuit held that Battlefield's deduction of capital expenditures breached the lease, and the failure to separately state charges also breached the lease. The court affirmed the district court's finding that security costs were common area maintenance costs. The case was remanded for further proceedings to correctly identify deductible administrative costs and recalculate damages. The appellate court granted the parties' joint motion to supplement the record. View "Cedar Hills Investment Co. v. Battlefield Mall, LLC" on Justia Law

Barton Hankins was hired by Crain Automotive Holdings, LLC in 2019 as Chief Operating Officer and was offered a deferred compensation plan (DCP). After four years, Hankins resigned and sought compensation under the DCP, which Crain denied. Hankins then filed a lawsuit under the Employee Income Retirement Security Act of 1974 (ERISA) to claim his benefits. The DCP stipulated that Hankins could earn a percentage of Crain’s fair market value upon his exit, with full vesting at five years. Having served four years, Hankins was entitled to 80% of the benefits.The United States District Court for the Eastern District of Arkansas granted judgment in favor of Hankins, concluding that the DCP did not require the creation of an Employment Agreement or a Confidentiality, Noncompete, and Nonsolicitation Agreement for enforceability. The court found that Crain’s claims of misconduct by Hankins were unsubstantiated and awarded Hankins attorney’s fees, determining that Crain’s conduct was sufficiently culpable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s judgment, holding that Crain’s interpretation of the DCP was unreasonable. The court found that the DCP’s Article 4, which mentioned the Employment and Confidentiality Agreements, did not create a condition precedent but rather a condition subsequent. The court also upheld the award of attorney’s fees, noting that Crain’s actions lacked merit and were raised only after Hankins sought his vested compensation. The appellate court concluded that the district court did not abuse its discretion in its rulings. View "Hankins v. Crain Automotive Holdings, LLC" on Justia Law

First Baptist Church, located in Fort Smith, Arkansas, had property insurance policies with Zurich American Insurance Company. The church experienced leaks over the years and hired roofing companies to repair portions of its roofing system in 2016, 2017, and 2018. In 2022, a roofing company representative determined the roofing system had hail damage, and First Baptist filed a claim with Zurich, alleging the damage occurred on April 28, 2017. Zurich denied the claim, citing no damage from the alleged hail event and evidence of excluded causes such as wear and tear. First Baptist sued Zurich for breach of contract and insurance bad faith.The United States District Court for the Western District of Arkansas granted summary judgment in favor of Zurich, concluding that First Baptist failed to comply with the prompt notice provision in the insurance policy. The court based its decision on evidence first discussed in Zurich’s reply brief, which indicated that First Baptist knew of past loss or damage to its property as early as 2016. The court held that no reasonable jury could find that First Baptist promptly notified Zurich of the loss or damage nearly six years later in January 2022. First Baptist filed a motion to reconsider, which the district court denied.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that there were potential genuine disputes of material fact not properly litigated. The court noted that First Baptist did not have a fair opportunity to counter Zurich’s evidence and arguments about past leaks and repairs. The court reversed the district court’s grant of summary judgment and remanded the case for further consideration of the issues related to past loss or damage and the effect on First Baptist’s claims. The court also reversed and remanded the grant of summary judgment on First Baptist’s bad faith claim. View "First Baptist Church v. Zurich American Insurance Co." on Justia Law

Sioux Steel Company, a South Dakota corporation, designed and manufactured a new line of hopper bins for grain storage. After selling one of these bins to a distributor in Mexico, the bin failed catastrophically, causing fatalities and property damage. Sioux Steel had an insurance policy with the Insurance Company of the State of Pennsylvania (ISOP), which included a professional services exclusion. ISOP denied coverage based on this exclusion, leading Sioux Steel to settle with the affected party without ISOP's involvement.The United States District Court for the District of South Dakota granted summary judgment in favor of ISOP, finding that the professional services exclusion in the insurance policy was unambiguous and applicable, thus precluding coverage. The court also dismissed Sioux Steel's claims for bad faith, punitive damages, and attorney's fees.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the professional services exclusion was clear and unambiguous. The exclusion applied because the damage arose from professional engineering services provided by Sioux Steel's employee and an external engineering firm. The court also found that ISOP did not breach its duty to defend, as no civil proceeding or alternative dispute resolution process had been initiated with ISOP's consent. Consequently, Sioux Steel's claims for breach of contract and insurance bad faith were dismissed, and the district court's judgment was affirmed. View "Sioux Steel Company v. Ins. Co. of the State of PA" on Justia Law