Justia Contracts Opinion Summaries

After DSCI filed suit against the Kingdom of Saudi Arabia, the Kingdom removed the case to federal district court and filed a motion to dismiss the complaint on the grounds of forum non conveniens, pointing to the forum-selection clause in the parties' contract. In this case, the contract provided that the Board of Grievances, a Saudi Arabian administrative court, shall be the assigned settlement of any disputes arising out of the contract. The DC Circuit affirmed the district court's grant of the Kingdom's motion, holding that the contract's forum-selection clause is mandatory and the dispute thus belonged before the Board of Grievances. View "D&S Consulting, Inc. v. Kingdom of Saudi Arabia" on Justia Law

At the motion-to-dismiss stage, dismissal on statute-of-limitations grounds is permissible only if a plaintiff's claims are conclusively time-barred on the face of the complaint. The DC Circuit reversed the district court's determination that Capitol Services' lawsuit was barred by the statute of limitations because Capitol Services was on "inquiry notice" of defendant's alleged interference with its contract long before the limitations period expired.The record was inconclusive as to whether Capitol Services had knowledge of Vesta's role prior to August 28, 2014, three years before this suit against Vesta was filed. Therefore, when during that intervening period Capitol Services had inquiry notice of Vesta's potential role was an open factual question that could not be resolved at this time in the proceedings. Finally, Vesta's collateral estoppel claim failed because critical elements of collateral estoppel have not been established. View "Capitol Services Management v. Vesta Corp." on Justia Law

MEBA filed suit against Liberty, alleging that its contract with Liberty required the parties to submit the underlying dispute to arbitration. The district court ruled in favor of MEBA and granted judgment on the pleadings, compelling arbitration.The DC Circuit affirmed and held that the district court had jurisdiction over MEBA's claim under section 301 of the Labor Management Relations Act of 1947 (LMRA), which provides federal jurisdiction over suits for violation of contracts between an employer and a labor organization. In this case, MEBA's claims regarding the arbitrability of the dispute clearly fell within the district court's statutory jurisdiction. The court rejected Liberty's argument under the Garmon preemption doctrine, and held that federal courts retain jurisdiction over hybrid claims raising both contractual and representational issues. Finally, although jurisdiction was proper here, the court reversed and remanded because material facts remained in dispute regarding the existence of an applicable arbitration clause. View "District No. 1 v. Liberty Maritime Corp." on Justia Law

Commonwealth filed suit against two land surveyors, KCI and WMC, alleging breach of contract and negligence claims in connection with four allegedly defective surveys that the two entities delivered to ICG, a non-party to this litigation. Commonwealth alleged that KCI's and WMC's surveys failed to notice the full size of a twelve-inch encroachment, which ICG discovered on its property. The district court dismissed the complaint based on the three year statute of limitations.The DC Circuit reversed as to the first three counts of the complaint because the district court erred in dismissing them on statute of limitations grounds without applying the discovery rule. In this case, at the motion to dismiss stage, the court could not conclusively say that Commonwealth and ICG failed to exercise reasonable diligence in attempting to discover the encroachment's full size. Furthermore, it was premature to reject the possibility that Commonwealth's claims in counts one, two, and three did not accrue, at the earliest, until ICG discovered that the encroachment was twelve inches. View "Commonwealth Land Title Insurance Co. v. KCI Technologies, Inc." on Justia Law

The DC Circuit vacated its previous opinion and substituted the following opinion.Homeowners filed suit against their insurance company for breach of contract when the company refused to cover flood damage to homeowners' residence. Homeowners also filed suit against their cleaning-and-restoration company for failing to adequately remedy the damage and prevent mold. The district court granted summary judgment for the insurance company and transferred the remaining claim to the district court based on lack of personal jurisdiction. The DC Circuit held that it lacked jurisdiction to review the transfer order. The court affirmed the grant of summary judgment, holding that homeowners' claim against the insurance company failed under Delaware law where there was no dispute that homeowners were away from their beach home for over 72 hours, which under the clear terms of the policy means the flooding occurred while the house was "unoccupied." View "Katopothis v. Windsor-Mount Joy Mutual Insurance Co." on Justia Law

Plaintiff filed suit against defendants, alleging breach of contract, defamation, and tortious interference with a prospective economic advantage. The district court granted summary judgment for defendants. In this case, plaintiff believed that she had voluntarily withdrawn from her postgraduate clinical research fellowship, but defendants reported to plaintiff's employer, the US Air Force, that she had been terminated for cause. The DC Circuit held that, because there was a genuine factual dispute as to whether defendants gave plaintiff's employer false information, the district court incorrectly granted summary judgment on the defamation claims. Therefore, the court reversed and remanded as to those claims. The court affirmed the district court's grant of summary judgment on the remaining claims. View "Burns v. Levy" on Justia Law

Hensel Phelps filed suit alleging breach of contract and indemnification claims against Marriott for, among other things, failing to meet the applicable standard of care and by failing to design the Project in accordance with applicable fire codes. The DC Circuit affirmed the district court's grant of summary judgment to Cooper Carry, holding that the statute of limitations has run on Hensel Phelp's breach of contract claim, and the terms of the indemnification clause did not cover first party claims. View "Hensel Phelps Construction Co. v. Cooper Carry Inc." on Justia Law