Justia Contracts Opinion Summaries

The Eighth Circuit affirmed the district court's dismissal of Air Evac's claims in an action alleging that Arkansas Blue inadequately reimbursed Air Evac for ambulance services that Air Evac provided Arkansas Blue plan members. The court held that Air Evac's assignment did not convey the right to sue for equitable relief under section 1132(a)(3) of the Employee Retirement Income Security Act (ERISA). Furthermore, the district court did not err by finding that Arkansas Blue's conduct was not actionable because it fell within the Arkansas Deceptive Practices Act's safe harbor for actions or transactions permitted under the laws administered by the insurance commissioner. Finally, the district court did not err by rejecting Air Evac's claims for breach of contract and unjust enrichment. View "Air Evac EMS, Inc. v. USAble Mutual Insurance Co." on Justia Law

The absence of a judgment in the state court litigation does not mean that plaintiff lacks Article III standing to bring this suit. Enterprise filed suit against several defendants, alleging a claim under the Missouri Uniform Fraudulent Transfer Act. The district court dismissed the complaint without prejudice based on the ground that there was no case or controversy because Enterprise lacked Article III standing.The Eighth Circuit reversed and held that Enterprise has alleged facts sufficient to demonstrate the elements of standing. In this case, Enterprise has sufficiently alleged a present injury in fact, fairly traceable to defendants, as the transferees of the funds. Therefore, the court remanded for further proceedings. View "Enterprise Financial Group Inc. v. Podhorn" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's Missouri state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and fraudulent misrepresentation against St. Louis University. Plaintiff's claims stemmed from his unsuccessful attempts to receive a Ph.D from the university in mechanical and aerospace engineering in four years.The court held that the educational malpractice doctrine barred all of plaintiff's claims. In this case, all of the statements plaintiff relied on in the student catalog and handbook were aspirational in nature. The court also held that the district court did not abuse its discretion by denying plaintiff leave to amend his complaint when he did not submit a proposed amendment or include anything in his motion to indicate what an amended complaint would contain. View "Soueidan v. St. Louis University" on Justia Law

A group of customers filed suit against SuperValu after hackers accessed customer financial information from hundreds of grocery stores operated by defendant. The Eighth Circuit previously affirmed the dismissal of all but one of the suit's named plaintiffs for lack of standing and, on remand, the district court dismissed the remaining plaintiff for failure to state a claim and denied plaintiffs' motion for leave to amend.The court affirmed, holding that the district court did not abuse its discretion by denying the motion for leave to amend because plaintiffs' postjudgment motion was untimely. The court also held that the remaining plaintiff's allegations fell short of stating a claim for relief under Illinois law for negligence, consumer protection, implied, contract, and unjust enrichment. View "Alleruzzo v. SuperValu, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial, on remand, of Qwest's unjust enrichment claim against FC. The court held that the district court did not abuse its discretion by concluding that it would not be inequitable for FC to retain the benefit conferred by Qwest. In this case, the district court explained that FC earned the benefit conferred by Qwest because it provided conference-calling services, 24-hour customer support, and access to a website in exchange for two cents per minute for calls placed to FC's conferencing bridges at Sancom. Furthermore, Qwest paid its own conference-calling vendor between two and four-and-a-half cents per minute. View "Qwest Communications Corp. v. Free Conferencing Corp." on Justia Law

The Eighth Circuit affirmed the district court's judgment holding that defendant was liable for amounts owed in a consent judgment stemming from loan defaults. Defendant had signed a general guaranty for a company that he thought he owned in part with his trusted friend and financial advisor. His friend purportedly failed to mention that the guaranty would make defendant liable for millions of dollars of debt from loans that his friend had obtained and was unable to pay.The court held that the FDIC's creation of CADC and its sale of Premier Bank's assets thereto fell within its broad power; there was no clear error in finding that defendant's agent delivered the guaranty with his implied actual authority because defendant signed the guaranty, understood its contents, and gave express authority to conduct business; and there was no error in finding that the bank did not fail in its duty to ensure that the agent acted with implied actual authority and in rejecting defendant's fraud in the factum defense. View "Radiance Capital Receivables Eighteen, LLC v. Concannon" on Justia Law

The Eighth Circuit affirmed an adverse order by the FAA's Office of Dispute Resolution for Acquisition (ODRA) regarding property Southern leased to the Administration. Southern subsequently sold the property and surrounding land to Prairie Land, assigning its lease with the FAA to Prairie Land. After the FAA refused to vacate the premises, Prairie Land initiated a contract dispute with the ODRA.The court held that the FAA's continued occupancy of the property was permitted, and the ODRA did not err by concluding that the holdover provisions permitted the FAA to holdover on the property until either a new lease was agreed upon or it acquired the property in fee. Therefore, the FAA was fully within its rights to continue possessing the property. View "Prairie Land Holdings, LLC v. FAA" on Justia Law

After Mako acquired a historic building with intentions to restore it using state and federal historic tax credits, it retained the law firm of Winthrop & Weinstine to draft the tax credit bond. CRBT then retained Winthrop to represent it in connection with the building tax credit project. CRBT, through counsel Winthrop, later sought to foreclose on the building. Mako retained separate counsel and moved to dismiss the complaint and to disqualify Winthrop. The district court denied both of Mako's motions and awarded $5.2 million to CRBT.The Eighth Circuit held that the district court did not err by denying Mako's motion to dismiss the action for failure to join Chevron as a necessary party under Federal Rule of Civil Procedure 19(a)(1); the district court did not err in calculating the money judgment; and, although the district court erred in failing to disqualify Winthrop as counsel for CRBT, the error was harmless. Accordingly, the court affirmed the district court's judgment for money damages; reversed the district court's denial to disqualify counsel in any future proceedings; and, as proceedings continue and the Winthrop law firm has a conflict of interest necessitating removal as counsel, remanded for further proceedings. View "Cedar Rapids Bank & Trust Co. v. Mako One Corp." on Justia Law

CMI, a purchaser and reseller of mortgage loans, filed suit against Platinum, an originator and seller of mortgage loans, alleging that Platinum breached a contract by failing to repurchase seven allegedly defective loans after CitiMortgage demanded repurchase by sending multiple notices to Platinum for each loan. The Eighth Circuit reversed and held that CMI adequately and substantially complied with the contract, which neither specified a form of notice nor indicated that the prescription of a time for cure had to be contained within the notice. Accordingly, the court remanded for further proceedings. View "CitiMortgage, Inc. v. Platinum Home Mortgage, Corp." on Justia Law

The District filed suit alleging that an UV System installed at one of its treatment facilities had consistently failed to function in any working capacity. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing the District's claims. The court held that the breach of warranty claim was properly dismissed because the District failed to present expert testimony to establish that the UV System's ongoing operational issues were caused by equipment defects. Furthermore, the express warranty provided that the District's exclusive remedy was replacement of the defective parts, but the District did not allow Evoqua, the UV System vendor, to repair or replace the warranty items. Finally, the district court did not err by dismissing the District's claim against Travelers, the project's contractor, under its Performance and Maintenance Bond. View "Iowa Great Lakes Sanitary District v. Travelers Casualty and Surety Co." on Justia Law