Justia Contracts Opinion Summaries

Bank of America filed suit against the Hanna Parties for breach of contract after they failed to pay a loan. The jury found that the Hanna Parties did not breach the contract and the district court entered judgment for them. On remand, the Hanna Parties advanced defenses of fraudulent inducement and fraudulent failure to disclose. The Eighth Circuit affirmed the district court's grant of the Bank's motion for summary judgment on those defenses because JB Hanna could not have reasonably relied on the Bank's allegedly fraudulent representations. In this case, the district court correctly rejected the defenses of fraudulent inducement and fraudulent failure to disclose as a matter of law. Furthermore, because there was insufficient evidence to support the fraud defenses, the setoff defense also failed. View "Bank of America v. JB Hanna, LLC" on Justia Law

Paris Limousine filed suit against Executive Coach, alleging that limousines it purchased from Executive Coach were in breach of warranty. The Eighth Circuit reversed the district court's dismissal of the complaint, holding that Paris Limousine brought its express warranty claim under Missouri law, which authorizes private enforcement actions for breaches of express warranties. The National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act), 15 U.S.C. 1381 et seq., and the Federal Motor Vehicle Safety Standards did not affect Executive Coach’s potential liability under Missouri law for breach of its express warranty. The court also held that Executive Coach had not met its burden to demonstrate that conflict preemption applied, and that Paris Limousine had alleged legally cognizable damages. View "Paris Limousine of OK, LLC v. Executive Coach Builders, Inc." on Justia Law

After Enerplus mistakenly overpaid mineral royalties to defendant and demanded repayment, defendant filed suit in tribal court. Enerplus then filed suit in federal court, seeking the return of the excess funds and a declaration that the tribal court lacked jurisdiction over the dispute. The Eighth Circuit affirmed the district court's decision to preliminarily enjoin defendant from proceeding with his case in tribal court. In this case, the contracting parties agreed that any disputes arising under the settlement agreement would be resolved in federal district court. Therefore, defendant could not bring suit arising from or related to the settlement agreement in the tribal court based on the forum selection clause. The court rejected defendant's bare assertion that Enerplus lacked standing to enforce the forum selection clause. View "Enerplus Resources (USA) Corp. v. Wilkinson" on Justia Law

The Eighth Circuit affirmed the district court's holding that an independent-contractor agreement's noncompete provision was unreasonable and therefore unenforceable. Without controlling precedent from the Iowa Supreme Court, the court predicted that the Iowa Supreme Court would hold that the enforceability of a noncompete provision was a question for the court. In this case, plaintiff developed his own customer base and received only minimal support from Ag Spectrum. The court explained that requiring plaintiff to forsake the customers that he brought to Ag Spectrum as an independent contractor was unreasonable in the circumstances, and plaintiff's business activity fostered fair competition in the marketplace, not unjust enrichment. View "Ag Spectrum Co. v. Elder" on Justia Law

Plaintiffs Lenny and Tracy Chapman filed suit against Hiland after an explosion seriously injured Lenny, alleging negligence and loss of consortium. Hiland then filed a third-party complaint against Missouri Basin and B&B, seeking indemnification. In this appeal, Missouri Basin challenged the district court's grant of summary judgment to plaintiffs and the district court's ruling on post-judgment motions. The Eighth Circuit held that honoring the Oklahoma choice-of-law provision in the Hiland Master Service Contract did not violate a fundamental public policy of North Dakota because it was not a motor carrier transportation contract under North Dakota law. The court also held that the district court did not abuse its discretion by granting plaintiffs' Fed. R. Civ. P. 59(e) motion where the district court clarified that by using the language "all amounts that have been paid or will be paid," Missouri Basin intended that it indemnify plaintiffs for the full amount of the settlement, including those amounts paid by Hiland's insurers. Furthermore, the district court did not abuse its discretion by denying Missouri Basin's Rule 59(e) motion. View "Chapman v. Missouri Basin Well Service" on Justia Law

Stine Seed filed suit against A&W and its principles, alleging contract claims related to A&W's failure to pay for corn and soybeen seed. The district court found in favor of Stine Seed on its implied-in-fact contract claim against Defendant Williams in the amount of $28,160, and found in favor of Williams and A&W on the remaining claims. The Eighth Circuit affirmed in part and held that the district court did not clearly err in finding that Williams did not sign the July Adjustment and in finding Williams' version of events credible; no implied-in-fact contract existed between Williams and Stine Seed with respect to the seed planted by J&A; and the district court did not err in finding Williams not liable for unjust enrichment. The court held, however, that the district court should have given A&W's admission that Alexander had apparent authority conclusive effect, and its finding that Alexander lacked authority to bind A&W to the Note was clear error. Therefore, the verdict in favor of A&W on Stine Seed's breach of contract claim must be reversed and remanded. View "Stine Seed Co. v. A & W Agribusiness, LLC" on Justia Law

The Eighth Circuit affirmed the district court's order compelling arbitration and dismissing plaintiff's case without prejudice where he alleged violations of minimum wage laws, as well as fraud. In this case, plaintiff signed a Volunteer Release, Waiver and Indemnification Agreement when he volunteered as a concession worker for a fundraiser. The court held that the agreement was not unconscionable under Missouri law because the agreement was easy to understand, with no evidence that it was non-negotiable. Furthermore, the agreement did not lack consideration where the consideration was that plaintiff was giving up his right to sue in return for his opportunity to volunteer and DNCS's contribution to Washington University, something neither was legally bound to do. Finally, the underlying factual allegations were covered by the arbitration provision. View "Leonard v. Delaware North Companies Sport Service, Inc." on Justia Law

Plaintiff filed suit against his former employer, NCC, for breach of contract and alleging claims under the Nebraska Wage Payment and Collection Act. Applying Nebraska's two-part test to determine whether an agreement was voidable as a product of duress, the court held that there was, at least, a genuine issue of material fact as to whether the threat of termination would support a claim of duress. Therefore, the court remanded for a determination of this factual issue. The court also held that, considering all relevant circumstances then existing and viewing the facts in the light most favorable to plaintiff, the Term Sheet was unjust and thus voidable as a product of duress given the alleged pressure brought to bear on him to sign the Mutual Rescission and Term Sheet. Therefore, the district court erred by granting summary judgment for NCC on the breach of contract claim. Likewise, the district court erred in granting summary judgment for NCC on the state law claim. View "Gilkerson v. Nebraska Colocation Centers" on Justia Law

Class representatives challenged the district court's denial of their motion to enforce the settlement agreement in a securities settlement, and the district court's denial of a subsequent motion to alter or amend. The Eighth Circuit affirmed the district court's judgment and denied defendants' motion to dismiss. The court explained that this case continues to present a live controversy and the Stipulation explicitly granted that the district court would have continuing jurisdiction for the purposes of enforcing the agreement and addressing settlement administration matters. The court also held that the case was not prudentially moot where the district court has the ability to provide an effective remedy; the district court did not err in interpreting the Stipulation according to its unambiguous meaning and in holding that defendants complied with the Stipulation's payment obligations; and the district court did not err by holding that the meaning of the Stipulation was unambiguous as matter of law and, in doing so, the district court did not place a burden of proof on any party. View "Cromeans v. Morgan Keegan & Co." on Justia Law