Justia Contracts Opinion Summaries

Articles Posted in Wyoming Supreme Court
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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

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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

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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

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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

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The Supreme Court affirmed the decision of the district court granting summary judgment in favor of C.H. Yarber Construction in this action brought by West American Insurance Company seeking subrogation and asserting claims of negligence and breach of contract, holding that West could not pursue its claims against C.H. Yarber in subrogation.C.H. Yarber was the tenant leasing Profile Properties' commercial property in Cheyenne when the property sustained damage from a fire. West, the insurer of the property, covered Profile's fire damages and proceeded against C.H. Yarber in subrogation. The district court concluded that West could not pursue its claims in subrogation because D.H. Yarber was a co-insured under Profile's insurance policy. The Supreme Court affirmed, holding that because the relevant lease evidenced that Profile did not intend to look to C.H. Yarber to cover the insured loss, West could not pursue its claims against C.H. Yarber in subrogation. View "West American Insurance Co. v. Black Dog Consulting Inc." on Justia Law

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The Supreme Court affirmed the decision of the Board of Equalization upholding the final determinations of the Department of Revenue (DOR) increasing the taxable value of Jonah Energy LLC's natural gas liquids (NGL) production for 2014 through 2016, holding that Jonah was not entitled to relief on its allegations of error.On appeal, Jonah argued that the Board misinterpreted the NGL purchase agreement between Jonah and the purchaser of its NGL, Enterprise Products Operating LLC, by refusing to account for deficiency fees Jonah paid to Enterprise in determining the NGL's taxable value. The Supreme Court affirmed, holding (1) the Board did not misinterpret the NGL purchase agreement at issue; and (2) the Board did not err by failing to take the facts and circumstances surrounding execution of the purchase agreement into account when interpreting it because there was no basis for losing outside the four corners of the purchase agreement to determine its meaning. View "Jonah Energy LLC v. Wyo. Dep't of Revenue" on Justia Law

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The Supreme Court affirmed the judgment of the district court confirming the arbitration panel's finding that a non-compete clause Dr. Michel Skaf signed in his employment contract with Wyoming Cardiopulmonary Services (WCS) was unenforceable but that a previously-granted liquidation award was still valid, holding that there was no error.After WCS terminated Skaf for cause Skaf opened his own cardiology office. WCS sued Skaf for breaching the non-compete clause in the parties' employment contract. The arbitration found Skaf violated the noncompete clause and awarded WCS liquidated damages. The Supreme Court remanded the case. On remand, the arbitration panel again found in favor of WCS, that the non-compete clause was unenforceable, but that the liquidated damages award was still valid. The district court confirmed the award. The Supreme Court affirmed, holding (1) the panel did not commit manifest error by denying Skaf interest on his deferred compensation award; and (2) because Skaf did not previously appeal the panel's award, he was barred from doing so now. View "Skaf v. Wyo. Cardiopulmonary Services, P.C." on Justia Law

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The Supreme Court affirmed the district court's award of $21,643.65 in attorney fees and costs to DAPCPA RPO, a full-service public accounting firm, after the court concluded that Defendant breached a purchase and sale agreement (PSA) and a covenant not to solicit, holding that there was no error.Defendant, a former employee of DAPCPA RPO, formed a new firm and provided services to former DAPCPA RPO clients. DAPCPA RPO filed suit, alleging several claims. The district court granted summary judgment for DAPCPA RPO in part, concluding that the parties' PSA and covenant not to solicit were valid and enforceable contracts and that Defendant breached them. Ultimately, the Court awarded DAPCPA RPO a total of $21,643.65 in attorney fees and costs. The Supreme Court affirmed, holding that the district court did not abuse its discretion in determining that DAPCPA RPO was entitled to its fees and costs. View "Hensel v. DAPCPA RPO LLC" on Justia Law

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The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Laramie Investment Company and its owner and president, Brad Jackson (collectively, Defendants), and dismissing Plaintiffs' action for breach of contract, negligence, and "reasonable expectations," holding that there was no error in the proceedings below. Plaintiffs, who contracted with Defendants to obtain an insurance policy for their ranch and surrounding outbuildings, brought this suit two years after a tornado destroyed their home and an outbuilding. Plaintiffs discovered that the insurance policy did not cover the outbuilding or its contents but did not bring suit until the two-year anniversary of the tornado. The district court granted summary judgment for Defendants on statute of limitations grounds. The Supreme Court affirmed, holding (1) Jackson was a "professional" under Wyo. Stat. Ann. 1-3-107; (2) the statute of limitations began running when the insurance policy was issued; (3) the district court correctly granted Defendants' motion for summary judgment; and (4) the "continuous care doctrine" did not apply to the facts of this case. View "Falkenburg v. Laramie Investment Co." on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the trial court in favor of Charlene Hassler and award of attorneys' fees and costs in the amount of $70,410.36 to Hassler, holding that the district court abused its discretion by awarding attorneys' fees without explaining why those fees were reasonable.When Circle C Resources hired Hassler to provide services in her home for clients with developmental disabilities the parties executed a confidentiality and noncompetition agreement. After Hassler left Circle C she continued to provide services to one former client in her home. Circle C brought this action alleging breach of the noncompete provisions of the parties' contract. After a remand, the trial court entered judgment in favor of Hassler, after which it awarded her all requested fees and costs. The Supreme Court reversed the attorneys' fees, holding (1) Hassler I did not invalidate the attorneys' fees provision of the parties' confidentiality and noncompete agreement; and (2) the trial court abused its discretion by not addressing the lodestar test or applicable discretionary factors in its written order. View "Circle C Resources v. Hassler" on Justia Law