Justia Contracts Opinion SummariesArticles Posted in Wyoming Supreme Court
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
Jontra Holdings Pty Ltd v. Gas Sensing Technology Corp.
The Supreme Court reversed the final judgments against Plaintiffs, Australian investors, who sued Gas Sensing Technology Corporation (GSTC), a Wyoming-based oil and gas service company, for payment of loans Plaintiffs made to finance GSTC's operations in Australia, holding that the court erred in dismissing GSTC's counterclaims.The district court dismissed GSTC's counterclaims on grounds that they unduly complicated the action and were untimely filed. The jury found that Plaintiffs had breached the implied covenant of good faith and fair dealing and, therefore, awarded no damages on Plaintiffs' breach of contract claims. The Supreme Court reversed, holding (1) the district court erred in dismissing GSTC's claims on the ground that they unduly complicated the case; and (2) the court erred in failing to give effect to a pleading GSTC filed in federal court and in dismissing GSTC's counterclaims as untimely. View "Jontra Holdings Pty Ltd v. Gas Sensing Technology Corp." on Justia Law
Fuger v. Wagoner
In this property dispute, the Supreme Court reversed the judgment of the district court finding largely in favor of Larry Wagoner, holding that the oral contract between the parties in this case was void.Donald Fuger and Wagoner entered into an oral agreement to construct two buildings on a portion of the Fugers' property. When the buildings were completed Wagoner occupied one and rented the other for several years. Fuger and wife later sued Wagoner and his wife seeking to evict them from the property. Wagoner, in turn, sued the Fugers, alleging contract and equitable theories for ownership of one building and the underlying property. The district court held that an enforceable oral contract existed between Fuger and Wagoner and awarded Wagoner $302,234 plus post-judgment interest. The court did not reach Wagoner's equitable claims. The Supreme Court reversed, holding that the district court erred in finding that a valid oral contract between Wagoner and Fuger existed. The Court remanded for consideration of Wagoner's equitable claims. View "Fuger v. Wagoner" on Justia Law
Denbury Onshore, LLC v. APMTG Helium LLC
In this breach of contract action, the Supreme Court affirmed the judgment of the district court awarding APMTG over $35 million in damages and interest, holding that the district court did not err.Denbury Onshore, LLC agreed to deliver certain amounts of helium to APTMG each year. When Denbury failed to deliver the required amounts, it claimed its nonperformance was excused by two force majeure events. The district court concluded that Denbury had failed to show its non-performance was excluded by a force majeure event except for a period of thirty-six days. The Supreme Court affirmed, holding that the district court did not err in (1) deciding Denbury's request to terminate the parties' agreement under the doctrines of frustration of purpose and/or impossibility of performance; (2) deciding that Denbury had failed to prove its nonperformance between April 23, 2013 and December 30, 2013 was excused by a force majeure event; and (3) deciding that Denbury had failed to prove its nonperformance after mid-August of 2014 was excused by a force majeure event. View "Denbury Onshore, LLC v. APMTG Helium LLC" on Justia Law
Pilcher v. Elliott
The Supreme Court affirmed the district court's denial of a motion to set aside default judgment against it after it failed to answer a writ of garnishment, holding that, despite certain procedural infirmities, the district court did not err in denying the motion to set aside default judgment.After Monty Elliott obtained a judgment his efforts to collect led to a writ of garnishment of Sonny Pilcher's earnings from Rack's Gentlemen's Club, a business operated by CC Cowboy's Inc. The district court entered default judgment against CC Cowboys. Pilcher filed a motion to vacate default judgment, which the district court denied. The Supreme Court affirmed, holding that CC Cowboys waived its objection to personal jurisdiction by appearing in the proceeding without making that objection. View "Pilcher v. Elliott" on Justia Law