Justia Contracts Opinion Summaries

After James Walsh’s (Plaintiff) employment with Zurich American Insurance Company (Defendant) was terminated, he filed a complaint against Defendant, alleging breach of contract, willful violation of New Hampshire’s wage and hour law, and other claims based on Defendant’s substantial reduction of his incentive pay for a lucrative deal and failure to pay incentive on another deal. A jury found that Defendant willfully and without good cause withheld the compensation owed to Plaintiff and awarded him double damages and attorney’s fees. The First Circuit vacated the district court’s judgment insofar as it incorporated the jury’s verdict on one deal (the Great American Insurance Company, or GAIC, deal) and affirmed the judgment with respect to the other deal (the Automobile Protection Corp., or APCO, deal), holding (1) Defendant was not entitled to judgment as a matter of law on the breach of contract and wage claims; (2) the jury’s breach and willfulness findings stemming from Defendant’s withholding of incentive compensation for a deal made with GAIC were not in error; but (3) the district court erred in concluding that, if Plaintiff had an enforceable incentive plan when the deal was struck with APCO, Defendant lacked discretion as a matter of law to change Plaintiff’s incentive formula for that deal. Remanded. View "Walsh v. Zurich American Insurance Co." on Justia Law

This dispute arose out of contract for the shipment of used tires from Puerto Rico to Vietnam. Because it arrived late to Vietnam, the shipment accrued port storage charges, demurrage charges, and related administrative fees. The district court granted summary judgment to the carrier, Mediterranean Shipping Co., concluding that Best Tire Recycling, Inc. was the shipper, and therefore, pursuant to the bills of lading, was liable to Mediterranean for unpaid ocean freight charges, shipping container demurrage, port storage, and related administrative fees. Best Tire appealed, arguing that the parties’ course of conduct overcame the presumption that Best Tire, who was identified as “shipper” on all of the bills of lading, bore liability. The First Circuit affirmed, holding that because Best Tire was designated as the shipper on the bills of lading, there were no genuine issues of material fact as to whether Best Tire was the shipper. View "Mediterranean Shipping Co. v. Best Tire Recycling, Inc." on Justia Law

Plaintiff filed suit against Defendants resulting from the failure of material Defendants had supplied to Plaintiff. Specifically, Plaintiff alleged breach of contract, breach of implied and express warranties, and negligence. The jury returned a verdict against Defendants and awarded more than $7 million in damages to Plaintiff. The First Circuit affirmed, holding that the district court did not err by (1) denying Defendants’ motion to exclude Plaintiff’s damages expert; (2) allowing Plaintiff’s employees to testify concerning potential customers’ intent to purchase Plaintiff’s new product; and (3) denying Defendants’ motion for judgment as a matter of law, a new trial, or to alter or amend the judgment. View "Packgen v. Berry Plastics Corp." on Justia Law

While she was a student at Harvard Law School (HLS), Megon Walker was a member of the staff of the Journal of Law and Technology. During Walker’s final semester, concerns arose regarding a draft article (the Note) that Walker had written. After a hearing, the HLS Administrative Board (Board) found that the Note contained plagiarism. Walker received a formal reprimand, which ultimately appeared on her transcript. Walker graduated from HLS despite the reprimand, but the notation placed on transcript caused the loss of a lucrative employment offer. Walker filed suit against the President and Fellows of Harvard College, the then-Dean of Students at HLS, and the former Chair of the Board, seeking to have the notation removed from her transcript. The district court granted summary judgment in favor of Defendants on all counts. The First Circuit affirmed, holding that the district court correctly granted summary judgment against Walker on her claims of breach of contract and defamation. View "Walker v. Harvard University Fellows" on Justia Law

Medina & Medina, Inc., a Puerto Rico-based distributor of refrigerated food products, sued its principal, Hormel Foods Corp. Medina sought a declaration that Medina was the exclusive distributor of Hormel’s retail refrigerated products in Puerto Rico and alleged that Hormel violated an alleged exclusive distributorship agreement and hence Puerto Rico’s Dealer’s Contracts Act (Law 75) by selling Supreme Party Platters directly to Costco while bypassing Medina. Hormel counterclaimed, asserting that Medina was not an exclusive distributor. The district court ruled (1) Medina’s exclusivity claim was time-barred, and (2) notwithstanding the time bar for Medina’s exclusivity claim, Hormel’s sales of Supreme Party Platters to Costco violated Law 75. The First Circuit affirmed in part and reversed in part, holding (1) Medina’s exclusivity claim as presented was time-barred; but (2) the statute of limitations bar to recovery also extends to Medina’s Costco-related claim. View "Medina & Medina, Inc. v. Hormel Foods Corp." on Justia Law

Plaintiff entered an original song and music video to a variety of companies affiliated with Sony Music Entertainment (Sony) as part of a songwriting contest sponsored by Sony. Plaintiff later sued Sony alleging contract and intellectual property claims. The district court entered an order compelling arbitration and dismissed Plaintiff’s case with prejudice, concluding that the claims were subject to mandatory arbitration under the Federal Arbitration Act and that Plaintiff failed to make a cognizable claim under Fed. R. Civ. P. 12(b)(6). Plaintiff appealed, arguing that the district court erred in ruling that he failed to allege sufficient facts to support his claims. The First Circuit affirmed, holding that because the district court’s rulings that Plaintiff’s claims were subject to mandatory arbitration provided an independent basis for dismissing his claims, the Court did not need to address Plaintiff’s challenge to the district court’s decision to dismiss his complaint on factual sufficiency grounds. View "Cortes-Ramos v. Sony Corp. of America" on Justia Law

Appellant was indicted in three separate criminal cases for his involvement in various drug-related crimes. The parties eventually negotiated a plea deal that resolved the three criminal cases. The plea agreement memorialized a joint sentencing recommendation and contained a provision in which Appellant waived his right to appeal. After he was sentenced, Appellant appealed, arguing that the district court should have accepted the plea agreement’s guideline calculations. The First Circuit dismissed the appeal, holding Appellant’s appeal was barred by the appeal waiver, that the agreement’s sentence recommendation provision was not ambiguous, and that there was no breach of the plea agreement. View "United States v. Betancourt-Perez" on Justia Law

Patricia Cornwell, a well-known crime novelist, and her spouse filed suit against their former business managers Anchin Block & Anchin and the company’s principal, Evan Snapper, alleging New York state law claims of negligent performance of professional services, breach of contract, and breach of fiduciary duty. The jury returned a verdict in favor of Plaintiffs on all three claims and awarded Plaintiffs $51 million in damages. Thereafter, the district court vacated the jury’s decision, ruling that it had incorrectly instructed the jury and that Defendants’ statements to the Department of Justice (DOJ) were protected by a qualified privilege and therefore should not have been considered by the jury. The First Circuit reversed in part, holding (1) the district court correctly found that it incorrectly instructed the jury on New York’s statute of limitations for a breach of fiduciary duty claim; and (2) the district court erred in entering judgment as a matter of law for Defendants on the DOJ issue. Remanded for a new trial. View "Cornwell Ent., Inc. v. Anchin, Block & Anchin, LLP" on Justia Law

After seeking a mortgage modification under the Home Affordable Modification Program Plaintiff filed a complaint against Wells Fargo Bank, N.A. and Homeward Residential Inc., claiming breach of contract, unfair debt collection under Mass. Gen. Laws ch. 93A, and derivative equitable relief. A federal district court dismissed Plaintiff’s action in its entirety. The First Circuit vacated and remanded, holding that Plaintiff’s complaint sufficiently alleged that Defendants failed to offer her a mortgage modification in a timely manner and that Plaintiff had sufficiently pled damages for her Chapter 93A claim. On remand, the district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that Plaintiff’s breach of contract and Chapter 93A claims failed, and therefore, her derivative claim for equitable relief failed as well. View "Young v. Wells Fargo Bank, N.A." on Justia Law

Thomas and Frances Frangos (Plaintiffs) secured a loan and pledged their home as collateral to secure a promissory note issued to the lender. Plaintiffs defaulted on the mortgage twice. A foreclosure sale was scheduled, but on the eve of the sale, Plaintiffs filed suit. Plaintiffs sought an injunction permanently barring Bank of America, N.A. and New Penn Financial, LLC (Defendants) from foreclosing, as well as damages premised on an alleged breached of a provision in the mortgage agreement. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that the district court did not err in its judgment. View "Frangos v. Bank of America, N.A." on Justia Law