Justia Contracts Opinion SummariesArticles Posted in Wyoming Supreme Court
Kappes v. Rhodes
The Supreme Court reversed the order of the district court granting summary judgment in favor of Defendant on her counterclaim for breach of contract in this legal malpractice lawsuit, holding that there was a genuine issue of material fact as to whether the parties entered into a lawfully enforceable settlement agreement.The underlying lawsuit arose after the death of Plaintiff's mother when Defendant failed timely to file an application with the Wyoming Medical Review Panel and a wrongful death lawsuit. Defendant filed a counterclaim for breach of contract, alleging that the parties had entered into a valid agreement to settle the legal malpractice claim for $100,000. The district court granted summary judgment in favor of Defendant, concluding that the settlement agreement was enforceable. The Supreme Court reversed, holding that there was a genuine issue of material fact about whether the parties had a setting of the funds on the issue of who was settling and who would be bound by the settlement, precluding summary judgment. View "Kappes v. Rhodes" on Justia Law
Skyco Resources, LLP v. Family Tree Corp.
The Supreme Court affirmed in part and reversed in part the decision of the district court granting summary judgment to Family Tree Corporation and JD4, LLC (collectively, Family Tree) and dismissing Skyco Resources, LLP's complaint asserting claims for breach of contract, breach of the covenant of good faith and fair dealing, conversion, and fraud/intentional misrepresentation, holding that the district court erred in part.Skyco entered into an agreement with Family Tree for the purchase of mineral interests owned by Family Tree. Before closing, however, Skyco wrote a letter giving notice of its termination of the agreement and demanding a return of its earnest money. Because Skyco failed to comply with the agreement's termination provision Family Tree refused to return the earnest money. Skyco then sued for return of the earnest money. The district court granted summary judgment to Family Tree. The Supreme Court reversed in part, holding that the district court (1) erred in granting summary judgment for Family Tree on Skyco's claim for return of its earnest money; and (2) properly granted summary judgment for Family Tree on Skyco's remaining claims. View "Skyco Resources, LLP v. Family Tree Corp." on Justia Law
Hassler v. Circle C Resources
The Supreme Court reversed the judgment of the district court ruling that Charlene Hassler had breached a court-modified agreement and granting summary judgment for Circle C Resources on its breach of a noncompete agreement claim, holding that the blue pencil rule is no longer permitted to make noncompete agreements reasonable.When she was hired by Circle C as a nursing assistant Hassler signed a noncompetition agreement prohibiting Hassler from soliciting Circle C's clients for twenty-four months after their employment relationship ended. After Hassler was hired by a new provider Circle C brought this action seeking damages for breach of the noncompete agreement. The district court granted summary judgment for Circle C, concluding that the noncompete agreement was reasonable enforceable if the geographical area subject to restriction were narrowed. The court then narrowed the restrictions accordingly. The Supreme Court reversed, holding (1) this Court no longer permits use of the blue pencil rule to make noncompete agreements reasonable; and (2) because the duration and geographical terms of the noncompete agreement were unreasonable the entire agreement was void in violation of public policy. View "Hassler v. Circle C Resources" on Justia Law
Malave v. Western Wyoming Beverages, Inc.
The Supreme Court reversed the judgment of the district court ruling that Western Wyoming Beverages, Inc. (WWB) would likely succeed on the merits of its claim that Jorge Malave, its employee, had breached his noncompete agreement that the WWB would suffer irreparable harm of Malave were not enjoined from continuing to work for WWB's competitor, holding that the district court erred.The district court concluded that there was a valid and reasonable noncompete agreement between the parties and that WWB would likely succeed on the merits of its claim that Malave had violated the agreement and would suffer possible irreparable injury if no injunction were entered. The Supreme Court reversed, holding that WWB did not meet its burden of proving probable success on the merits of the reasonableness of its noncompete agreement with Malave. View "Malave v. Western Wyoming Beverages, Inc." on Justia Law
Bergantino v. State Farm Mutual Automobile Insurance Co.
The Supreme Court affirmed the decision of the district court granting summary judgment in favor of State Farm Mutual Automobile Insurance Company and dismissing Plaintiffs' claim alleging that they were entitled to uninsured motor vehicle (UIM) benefits after they were injured in an automobile accident caused by another driver, holding that State Farm was entitled to judgment as a matter of law.After their accident, Plaintiffs filed claims with State Farm for full UIM benefits of $100,000 after settling with the tortfeasor's insurance company. When State Farm did not respond, Plaintiffs brought suit, asserting breach of contract, bad faith in delaying and denying payment for the benefits, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment for State Farm. The Supreme Court affirmed, holding that under the unambiguous language of the State Farm insurance policy, Plaintiffs were not entitled to UIM benefits and were not entitled to relief on their claims. View "Bergantino v. State Farm Mutual Automobile Insurance Co." on Justia Law
Skaf v. Wyoming Cardiopulmonary Services, P.C.
The Supreme Court denied Wyoming Cardiopulmonary Services's (WCS) motion to dismiss this appeal of the district court's confirmation of the decision of an arbitration panel concluding that the parties' non-compete agreement was enforceable if modified and reversed the confirmation of the panel's decision, holding that the panel made a manifest error of law.Dr. Michel Skaf, a cardiologist, signed a non-compete agreement when he became a shareholder in WCS. After WCS terminated Dr. Skaf for cause, he set up his own practice. WCS subsequently brought this complaint and a motion to compel arbitration. The panel found that the covenant not to compete was enforceable if modified and rewrote the agreement. The district court confirmed the panel's decision to enforce the covenant not to compete and entered judgment of $193,000. The Supreme Court reversed and vacated the award, holding that the panel made a manifest error of law in violation of public policy in its review and revision of the covenant not to compete. View "Skaf v. Wyoming Cardiopulmonary Services, P.C." on Justia Law
Brown v. Best Home Health & Hospice, LLC
The Supreme Court reversed the judgment of the district court granting a preliminary injunction sought by Best Home Health & Hospice, LLC (Best Home) to prohibit three registered nurses (collectively, the Nurses) who left Best Home's employ and began working for a competing company, from working for Best Home's competitor, holding that the district court abused its discretion.The Nurses in this case quit working for Best Home and went to work for one of Best Home's competitors. Best Home sued them for breach of the non-compete provision in their employment contracts and requested a preliminary injunction to prohibit them from working for its competitors. The district court enjoined the Nurses from working for Best Home's competitors. The Supreme Court reversed, holding (1) Best Home did not show it was likely to succeed in establishing that the non-compete provision was consistent with public policy, and therefore, the district court abused its discretion by enjoining the Nurses from working for Best Home's competitors; and (2) the district court abused its discretion in refusing to allow the Nurses to present evidence on how enforcement of the non-compete provision would harm the public interest. View "Brown v. Best Home Health & Hospice, LLC" on Justia Law
Page v. Meyers
The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims for negligent misrepresentation and intentional interference with a contract, holding that Defendants were entitled to summary judgment.Plaintiff sued Defendants, her adult stepchildren, claiming that they caused their father - and Plaintiff's late husband - to remove Plaintiff as the primary beneficiary of his insurance plan. The district court determined that Plaintiff failed to present evidence to establish any genuine dispute of material fact for trial and awarded summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff failed to establish a dispute of material fact as to whether Defendants supplied false information and as to whether a valid contract existed between her and Defendants. View "Page v. Meyers" on Justia Law
Sinclair Wyoming Refining Co. v. Infrassure, Ltd
The Supreme Court answered in the affirmative a question certified to it by the United States Court of Appeals asking whether an insurance policy is "issued for delivery" or "delivered" under Wyo. Stat. Ann. 26-15-101(a)(ii) even if not copy was conveyed to Wyoming and the police listed only an out-of-state address for the insured.Specifically, the Supreme Court held (1) for purposes of Wyo. Stat. Ann. 26-15-101(a)(ii), an insurance contract is "delivered" in Wyoming if it is actually or constructively delivered in Wyoming, and an insurance contract is "issued for delivery" where the policy was intended to be delivered; and (2) absent an insurance contract unambiguously stating otherwise, if the location of the insured and the location of the risk to be insured are both in Wyoming, an insurance policy is intended to be delivered and is issued for delivery in Wyoming. View "Sinclair Wyoming Refining Co. v. Infrassure, Ltd" on Justia Law
Davidson-Eaton v. Iversen
The Supreme Court dismissed this appeal for want of jurisdiction, holding that no final order had been entered in this matter.The co-personal representatives of the Estate of Gale S. Iverson sued Cheri Eaton, Iverson's former caretaker, seeking to recover property that the Estate alleged Eaton unlawfully transferred to herself. The Estate requested that Eaton be ordered to provide the Estate an accounting. Eaton, in turn, sued the Estate in a separate action for breach of express and implied contract and quantum meruit. The district court consolidated the actions, denied Eaton's claims, and ordered that Eaton provide the Estate an accounting. Eaton appealed. The Supreme Court dismissed the appeal for want of jurisdiction, holding that no final order had been entered in this matter. View "Davidson-Eaton v. Iversen" on Justia Law