Justia Contracts Opinion Summaries

In this case, Four Thirteen, LLC filed a complaint against three corporate entities and several individuals, including Joshua Wearmouth, Larry Stephens, Edmond X. Moriniere, Ronald G. Meyers, and David C. Norton. The complaint alleged that Wearmouth and Stephens solicited funds from Four Thirteen for a business venture involving Brazilian carbon credits, which turned out to be fraudulent. Four Thirteen claimed that the corporate entities did not own the carbon credits and that Wearmouth and Stephens made numerous misrepresentations. The complaint included claims of breach of contract, fraud, negligent misrepresentation, and other related allegations.The District Court of Laramie County reviewed the case and rejected the affidavits of non-involvement filed by Moriniere, Meyers, and Norton, who sought dismissal from the suit. The court found that there were factual issues regarding their involvement in the alleged fraud. Additionally, the district court imposed discovery sanctions and entered a default judgment against all defendants, including the individual appellants, for failing to comply with discovery orders.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision regarding the affidavits of non-involvement. The Supreme Court determined that the district court correctly found that there were factual disputes about the involvement of Moriniere, Meyers, and Norton, which precluded their dismissal from the case.However, the Supreme Court reversed the district court's decision to impose discovery sanctions against the individual appellants. The Supreme Court found that the appellants were not given proper notice that they were subject to sanctions under Wyoming Rule of Civil Procedure 37(b) and that there was no evidence they violated any prior discovery order. The court held that the sanctions against the individual appellants were not justified and remanded the case for further proceedings consistent with its opinion. View "Stephensv. Four Thirteen, LLC" on Justia Law

Casey and Janae Ruppert entered into a contract to purchase ranch property from Judith Merrill. Before closing, Merrill indicated she would not proceed with the sale. The Rupperts filed a complaint seeking specific performance and damages. The district court found Merrill breached the contract and denied her affirmative defenses. It awarded the Rupperts damages and attorneys’ fees but declined to order specific performance. The Rupperts appealed the denial of specific performance, and Merrill cross-appealed the attorneys’ fees award.The District Court of Laramie County found Merrill breached the contract but declined to order specific performance, citing Merrill’s personal circumstances and misunderstandings about the contract. It awarded the Rupperts $22,342 in damages and granted their motion for attorneys’ fees without explanation, awarding $55,258.50 in fees and $3,082.60 in costs.The Wyoming Supreme Court reviewed the case and found the district court abused its discretion by denying specific performance. The court noted the district court’s findings contradicted its decision, as it found the contract valid, the price reasonable, and no undue influence or unconscionability. The Supreme Court held that specific performance was the appropriate remedy given the circumstances and the equities involved.Regarding attorneys’ fees, the Supreme Court agreed with both parties that the district court erred by awarding fees without explanation. The Supreme Court independently assessed the reasonableness of the fees, concluding that the rates charged were excessive for the local market. It reduced the hourly rate to $250, resulting in a total fee award of $28,425.00, plus the previously awarded costs of $3,082.60.The Wyoming Supreme Court reversed the district court’s orders denying specific performance and awarding attorneys’ fees, remanding the case for entry of an order consistent with its opinion. View "Merrill v. Ruppert" on Justia Law

Kerry and Jeanie Cooper entered into a five-year lease agreement with James and Melisa Crouch to lease farmland for pasturing cattle and growing crops. The lease was set to expire in February 2022, but the Crouches terminated it early, citing the Coopers' failure to employ standard best management practices. The Coopers filed a lawsuit for breach of contract, claiming they were not given adequate notice or an opportunity to cure any alleged default as required by the lease.The District Court of Fremont County found that the Crouches breached the lease by failing to provide the required notice and opportunity to cure. The court awarded the Coopers $153,772.05 in damages, which included costs for feed, supplements, trucking, and replacement pasture. The court also reduced the damages by $24,650.35 for the Coopers' failure to mitigate damages by selling leftover hay.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that the Crouches did not provide the Coopers with a meaningful opportunity to cure the alleged default, as the termination letter did not specify how to remedy the issues. The court also rejected the Crouches' first-to-breach defense, stating that they could not rely on the Coopers' alleged breach to excuse their own failure to provide proper notice.However, the Supreme Court found that the district court had erroneously included the costs of the pasture leases twice in its damages calculation. The court remanded the case with instructions to reduce the damages award by $2,660.60, affirming the decision in all other respects. View "Crouch v. Cooper" on Justia Law

Donald and Mary Fuger own forty acres of land in Wyoming. Larry Wagoner began using a five-acre section of this land for his oilfield business around 2008. The Fugers and Wagoner agreed to construct two buildings on the site, with Wagoner handling construction and the Fugers securing financing. They did not formalize this agreement in writing. A lease agreement was signed, giving Wagoner exclusive use of the buildings for five years. Wagoner claimed there was an oral agreement to transfer ownership of one building and the land to him in exchange for his construction work and loan payments, which the Fugers denied.The District Court of Sweetwater County initially found in favor of Wagoner, awarding him damages for breach of the oral contract. However, the Wyoming Supreme Court reversed this decision in Fuger v. Wagoner, 2020 WY 154, ruling the oral contract void because Mrs. Fuger did not join the agreement. The case was remanded to consider Wagoner’s equitable claims. On remand, the district court found the Fugers were unjustly enriched by Wagoner’s construction work and awarded him damages, offsetting some of these due to his use of the buildings. The court also awarded prejudgment interest on a portion of the damages.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not err in offsetting Wagoner’s damages by the actual rent he received rather than the fair rental value of the second building. The court also upheld the award of prejudgment interest, finding that a portion of Wagoner’s damages were liquidated and thus subject to such interest. The court concluded that the district court acted within its discretion in its equitable determinations regarding offset and prejudgment interest. View "Fuger v. Wagoner" on Justia Law

Summit Construction filed a lawsuit against Jay Koontz and Jennie L. Kennette for breach of contract and unjust enrichment, alleging nonpayment for work performed on Mr. Koontz’s home based on an oral agreement. The work included an addition to the home and extensive renovations to the existing structure. The District Court rejected both claims, determining that there was no enforceable oral contract between the parties and that Summit did not sufficiently prove its damages for the unjust enrichment claim.The District Court found that the parties had not mutually agreed to sufficiently definite terms for an oral contract. The court noted that the project progressed without a clear understanding of the scope of work, how it would be paid for, and who would be responsible for payment. The court also found that Summit's invoices did not clearly define the terms of the contract. Furthermore, the court concluded that Summit had failed to prove the amount by which Mr. Koontz was unjustly enriched, i.e., its damages.Upon appeal, the Supreme Court of Wyoming affirmed the District Court's decision. The Supreme Court agreed that Summit had failed to show the existence of an enforceable oral contract with either Mr. Koontz or Ms. Kennette. The court also agreed with the lower court's finding that Summit had failed to establish its damages to a reasonable degree of certainty, which is necessary for an unjust enrichment claim. View "Summit Construction v. Koontz" on Justia Law

The case revolves around a dispute between Sharon Ann Koch, a member of the Buffalo Trail Ranch subdivision, and Melissa R. Gray, who was purchasing a tract in the subdivision. Koch, along with other members and the developer of the subdivision, Rocky Mountain Timberlands, Inc. (RMT), sued Gray for allegedly violating the subdivision's restrictive covenants by placing garbage, junk, and other prohibited items on her property. The covenants, filed by RMT in 2008, also required the formation of a road maintenance association, which was never established.The District Court of Albany County dismissed all claims against Gray, applying the contractual "first to breach" doctrine. The court reasoned that RMT, by failing to form the road maintenance association, was the first to breach the covenants. Therefore, it was impossible to hold Gray to the covenants. Koch appealed this decision, arguing that she had no contractual relationship with Gray, and thus the "first to breach" doctrine should not apply to her claim.The Supreme Court of Wyoming agreed with Koch. It found that the "first to breach" doctrine, which is based on a contractual relationship, could not be applied as there was no contract between Koch and Gray. The court also rejected the lower court's conclusion that RMT's breach of the covenants rendered them inapplicable to Gray. The court found no legal basis for applying the "first to breach" doctrine to a third party's enforcement of covenants. Consequently, the Supreme Court reversed the lower court's decision and remanded the case for further proceedings. View "Koch v. Gray" on Justia Law

In the Supreme Court of Wyoming, an appeal by Ronald Pinther, a former insurance agent, was dismissed. Pinther had worked for American National Property and Casualty Insurance Company (ANPAC) and American National Insurance Company (ANICO). He filed a lawsuit against ANPAC, ANICO, and another agent, Philip Maggard, claiming breach of contract, breach of good faith and fair dealing, fraudulent inducement, promissory estoppel, civil conspiracy, and age discrimination. The district court granted summary judgment in favor of ANPAC and Mr. Maggard. On appeal, the Supreme Court held that the district court had not erred in its decision. The court found that Mr. Pinther's breach of contract claim against ANPAC was governed by the Post-Termination Compensation Schedule outlined in the agent agreement. The court further held that Mr. Pinther's claim of a breach of an implied duty of good faith and fair dealing could not be maintained given the at-will nature of the agency contract. The court also dismissed Mr. Pinther's fraudulent inducement claim against ANPAC, noting that the recruiting brochure did not govern his agreement with ANPAC. The court further held that Mr. Pinther's claim for tortious interference with a contract against Mr. Maggard could not be maintained as the actions of Mr. Maggard, as an agent of ANPAC, were imputed to ANPAC. Lastly, the court held that Mr. Pinther's civil conspiracy claims against ANPAC and Mr. Maggard failed as the underlying tort claims did not survive summary judgment. View "Pinther v. American National Property and Casualty Insurance Company" on Justia Law

In this case from the Supreme Court of Wyoming, LFP Consulting, LLC (LFP), a financial advisory company, sued former employee David Edward Leighton for breach of contract and various torts after his resignation. The key issue was a clause in the parties' contract that selected Minnesota as the forum for disputes (a forum selection clause). LFP had filed the lawsuit in Wyoming and attached a waiver of the forum selection clause. However, the Wyoming chancery court dismissed LFP’s complaint for improper venue, concluding that LFP did not have the right to unilaterally waive the forum selection clause. The Supreme Court of Wyoming disagreed with the lower court, ruling that LFP, as the assignee of the contract, had the right to unilaterally waive the forum selection clause because it was included in the contract for the sole benefit of Ameriprise Financial, the original party to the contract with Leighton. The court also noted that Leighton had no relationship with Minnesota, which further supported the decision to allow LFP to waive the forum selection clause. The court reversed the decision of the chancery court and remanded the case for further proceedings. View "LFP Consulting, LLC v. Leighton" on Justia Law

In this case heard by the Supreme Court of the State of Wyoming, the plaintiff, Scherri Hacker, made a conversion claim against Hacker Oil, Inc., which had paid premiums on a whole life insurance policy on her husband, James Hacker. The policy was executed as a split-dollar arrangement, with the intention that upon Mr. Hacker's death, Hacker Oil would be reimbursed for the paid premiums, and the remaining death benefits would be distributed to Mrs. Hacker. After Mr. Hacker's death, Hacker Oil received $125,000 and half the interest accrued under the policy, which exceeded the $55,048 it had remitted in premium payments.The defendant, Hacker Oil, appealed the district court's decision, arguing that Mrs. Hacker had failed to mitigate her damages by withholding her signature from a letter agreement and by asserting a conversion claim against Hacker Oil. The court, however, upheld the district court's ruling, finding that Mrs. Hacker did not have a duty to mitigate her damages. The court determined that Mrs. Hacker's failure to sign the letter agreement prior to Hacker Oil's signing and submission of a claim to the insurance company did not constitute a failure to mitigate damages. The court further concluded that once Hacker Oil committed the conversion, Mrs. Hacker rightfully brought a claim and asserted her rights. Thus, the Supreme Court of the State of Wyoming affirmed the district court's decision, holding that Hacker Oil had wrongfully converted $70,372.68, the difference between the amount it received and the amount it was entitled to receive. View "Hacker Oil, Inc. v. Hacker" on Justia Law

The Supreme Court reversed the judgment of the district court denying Wind River Rehabilitation and Wellness's motion to compel arbitration in this action alleging medical malpractice, holding that the district court erred in denying the motion to compel arbitration.Plaintiff, the wrongful death representative of Loy Forshee, filed this action against Wind River, where Forshee lived when he fell and broke his hip, alleging medical malpractice. Wind River moved to compel arbitration under the parties' arbitration agreement. The district court denied the motion, concluding that Wind River waived his right to arbitration by waiting fourteen months to compel arbitration. The Supreme Court reversed, holding that the record did not support a conclusion that Wind River waived its right to arbitrate. View "Empres at Riverton, LLC v. Osborne" on Justia Law