Justia Contracts Opinion Summaries

Articles Posted in Utah Supreme Court
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Weston Bennion was injured when his apartment deck collapsed and subsequently sued his landlord, Dale Stolrow, for negligence. The parties settled, with Bennion agreeing to release Stolrow and his insurer from all claims in exchange for $150,000. The settlement was subject to related subrogation claims and healthcare liens, and Bennion promised to indemnify Stolrow from liability for any such claims and liens. Before making the payment, Stolrow informed Bennion that he intended to distribute the payment in two checks: one payable to Bennion and the other payable to a collection agency that had a healthcare lien on the settlement funds. Bennion objected and filed a motion to enforce the parties’ agreement, arguing that its terms did not allow Stolrow to issue a portion of the settlement funds to a third party.The district court disagreed with Bennion and suggested that Stolrow issue two checks: one jointly to Bennion and the third party for the amount of the lien, and another to Bennion for the remainder of the funds. The court of appeals affirmed the district court’s decision. Bennion then petitioned for certiorari.The Supreme Court of the State of Utah granted certiorari to address whether the court of appeals erred in concluding that the parties’ agreement permitted Stolrow to issue a portion of the settlement funds jointly to Bennion and the third-party collection agency. The court agreed with Bennion, stating that the plain language of the release provides for payment to Bennion in exchange for his release of claims against Stolrow and his assumption of responsibility for third-party liens. Therefore, the court reversed the decision of the lower courts. View "Bennion v. Stolrow" on Justia Law

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In this case, a doctor, Dr. Gabriel Fine, sued the University of Utah School of Medicine, alleging that the University deprived him of his clinical privileges without following the procedures required by its bylaws. The University moved for summary judgment, pointing to a provision in its bylaws where Dr. Fine had agreed not to sue "for any matter relating to appointment, reappointment, clinical privileges, or the individual’s qualifications for the same." The district court granted summary judgment in favor of the University, agreeing that Dr. Fine had released his claims against the University.Dr. Fine appealed the decision, arguing that the district court erred in interpreting the release to apply to his case. He asserted that the release only applied to actions taken during a formal review process and his claims arose from actions taken during an informal process.The Supreme Court of the State of Utah disagreed with Dr. Fine's argument. The court interpreted the release using its traditional tools of contract interpretation and found no textual justification for limiting the release's application only to actions taken during the formal review process. The court held that Dr. Fine’s claims against the University fell within the scope of the release and therefore affirmed the district court's decision. View "Fine v. University of Utah" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court concluding that the parties' signed voluntary declaration of paternity (VDP) should be set aside because of the parties' fraud and a mutual mistake but that Taylor Scott should nevertheless be adjudicated the child's father, holding that there was no error.Sarah Benson and Taylor Scott, an unmarried couple, signed a VDP representing that Scott was the father of Benson's child when both parties know that Scott was not the child's biological father. When Benson later cut off contact between Scott and the child Scott filed a complaint seeking joint legal and physical custody. In response, Benson challenged the VDP. The district court set aside the VDP but concluded that, under the Utah Uniform Parentage Act, Scott should be adjudicated to be the child's father. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court did not err in looking to the factors set forth in Utah Code 78B-16-608 to disregard the genetic test results that would have excluded Scott as the child's father. View "Scott v. Benson" on Justia Law

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In this real estate case, the Supreme Court affirmed the judgment of the district court dismissing this complaint brought by Rocky Mountain Hospitality, LLC (Seller) against Mountain Classic Real Estate, Inc. (Buyer) and awarded Buyer its attorney fees on appeal, holding that because Seller failed to release its interest in the deposit before filing its complaint it was barred from pursuing other remedies.Buyer entered into a contract with Seller to purchase a motel. The purchase price included an earnest money deposit. Buyer failed to purchase the motel. Seller brought this action seeking damages but failed to release its interest in the earnest money deposit before filing the complaint. The district court dismissed the complaint. The Supreme Court affirmed, holding (1) under the contract's default provision, Seller was obligated to release its interest in an earnest money deposit before filing a complaint if Seller wished to pursue a remedy other than liquidated damages; and (2) Seller was deemed to have elected to retain the deposit as liquidated damages and was barred from pursuing its claims. View "Rocky Mountain Hospitality v. Mountain Classic Real Estate, Inc." on Justia Law

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The Supreme Court affirmed the order of the district court awarding Defendant an additional $9,000 in attorney fees and $162 in costs in a second appeal after the first appeal resulted in an award of attorney fees and costs for Defendant totaling $26,413, holding that there was no error and that the award of attorney fees was proper.Plaintiff sued for unlawful detainer, breach of lease, and unjust enrichment. The district court granted summary judgment for Defendant but denied Defendant's request for attorney fees. The court of appeals reversed the ruling on attorney fees. On remand, the district court awarded Defendant attorney fees and costs totaling $26,413. The court of appeals affirmed. On remand, the district court awarded Defendant additional attorney fees and costs. The Supreme Court affirmed and granted Defendant's request for attorney fees incurrent on appeal, holding that Defendant was properly awarded his attorney fees in the district court and that Defendant was entitled to reasonable attorney fees that he incurred in defending against this appeal. View "Gardiner v. Anderson" on Justia Law

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The Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss this lawsuit brought by Plaintiff under the Utah Sales Representative Commission Payment Act for allegedly failing to pay commissions it owed to her, holding that the Act's writing requirement is not a precondition for recovery.In her complaint, Plaintiff claimed that Defendant violated the Act by failing to pay commissions for sales that she made while working as a commissioned sales agent for the company. Defendant filed a motion to dismiss, arguing that because there was no signed writing there could be no recovery under the Act. The district court granted the motion. The Supreme Court reversed, holding (1) under the plain text of the Act, the writing requirement is not a prerequisite for a sales representative to sue a principal under the Act; and (2) therefore, the district court erred in granting Defendant's motion to dismiss. View "Williamson v. MGS By Design, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the district court concluding that Bonner County, an Idaho political subdivision, had failed to demonstrate to Western Insurance Company's Liquidator that Pend Oreille Bonner Development LLC's failure to complete several municipal projects had cost it anything, holding that the court's finding were not against the clear weight of the evidence.Bonner County contracted with Pend Oreille to construct the projects at issue and required Pend Oreille to obtain multiple surety bonds, which Pend Oreille purchased through Western. Pend Oreille defaulted on the projects. Bonner County filed a claim with the Liquidator of Western, which had been placed in liquidation, to recover the surety bonds. The district court entered judgment against Bonner County. The Supreme Court affirmed across the Board, holding that the district court did not err when it (1) admitted extrinsic evidence to determine the parties' intent; (2) read the statute to provide that a liquidator can amend a determination of claims in response to charged circumstances; and (3) made its findings. View "Bonner County v. Western Insurance Co." on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court dismissing Honnen Equipment Company's (Honnen) breach of contract claim brought brought against Daz Management, LLC (LLC), holding that all elements of claim preclusion were met, and therefore, the breach of contract claim was barred.Honnen sued Tony Daz (Daz) claiming that Daz negligently operated and damaged a grader that had been rented by the LLC from Honnen and thus breached the rental agreement. The district court ruled for Daz on both Honnen's breach of contract and negligence claim. Thereafter, Honnen brought a second action against the LLC asserting the same claims. After Honnen voluntarily dismissed its negligence claim the district court dismissed the breach of contract claim under the claim preclusion branch of res judicata. The court of appeals reversed. The Supreme Court reversed, holding that Honnen's breach of contract claim was barred. View "Honnen Equipment Co. v. DAZ Management, LLC" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Ahhmigo, LLC's motion to vacate the arbitrator's ruling in favor of The Synergy Company of Utah, LLC in this breach of contract proceeding, holding that the district court did not err.Ahhmigo filed a complaint and demand for arbitration against Synergy, alleging breach of contract, unjust enrichment, and other climes. Synergy agreed to arbitrate Ahhmigo's claims, and the arbitrator ruled in favor of Synergy. Ahhmigo moved the district court to vacate the arbitration award, arguing that the arbitrator had manifestly disregarded the law. The district court denied the motion and confirmed the arbitration award. The Supreme Court affirmed, holding that this Court will not reach the question presented on appeal because Ahhmigo did not raise it in the district court. View "Ahhmigo, LLC v. Synergy Co. of Utah, LLC" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court compelling arbitration in this suit alleging breach of contract and breach of the covenant of good faith and fair dealing, holding that there was no error.Three doctors, including Lisa Pasquarello and John Artz, formed a limited liability company for their veterinary clinic and adopted an operating agreement that contained an arbitration clause. When Pasquarello tried to sell her portion of the practice to Artz through an oral agreement and the sale failed, Pasquarello brought this lawsuit against Artz. The district court compelled arbitration, concluding that the claims fell under the arbitration clause in the operating agreement. The court of appeals affirmed. The Supreme Court affirmed, holding (1) each of Pasquarello's claims related to the enforcement or interpretation of the operating agreement; and (2) therefore, court of appeals correctly held that the district court properly compelled arbitration. View "Hitorq, LLC v. TCC Veterinary Services, Inc." on Justia Law