Justia Contracts Opinion Summaries

In February 2011, two years and four months after Plaintiff learned she had been disinherited by her mother, Plaintiff filed a complaint against financial advisor Bradley Lott for fraud and constructive fraud. A jury found that Lott had committed constructive fraud but that Plaintiff knew or should have known before February 2007 that the fraud occurred. Based on the jury’s findings, the district court dismissed the action, concluding that Plaintiff’s claims were barred by the statute of limitations. The Supreme Court reversed the judgment, holding (1) the evidence did not support a finding that Plaintiff could have discovered the fraud sooner, and (2) therefore, the district court erred by dismissing the case based on the statute of limitations. Remanded for a new trial. View "Erdelyi v. Lott" on Justia Law

In 1997, the Courtenay C. Davis Foundation and Amy Davis (together, “Davis Interests”) entered into an agreement with the University of Wyoming Foundation and the Colorado State University Research Foundation (together, “University Foundations”) in which the Davis Interests donated land and other interests to the University Foundations subject to the terms of the agreement. In 2011, the University Foundations decided to sell the gifted property and listed it for sale. In 2012, the Davis Interests filed an action against the University Foundations seeking to enjoin the sale of the property. The district court dismissed the complaint for lack of standing. The Supreme Court affirmed, holding that the district court did not err in concluding that the donation from the Davis Interests to the University Foundations was a gift, that the agreement did not create an implied trust, and that only the attorney general had standing to enforce the terms of a charitable gift. View "Courtenay C. & Lucy Patten Davis Found. v. Colo. State Univ. Research Found." on Justia Law

Forsberg Engerman Co., an insurance agency, helped Lewis Holding Co., a trucking business, purchase insurance from Lexington Insurance Co. In 2011, one of Lewis Holding’s trailers was damaged. After Lewis Holding filed an insurance claim, NTA, Inc.’s adjuster examined the trailer and determined that the damage was due to mechanical failure or wear and tear. Lexington denied the insurance claim on the grounds that the damages were not the result of an upset or collision, but rather, the result of improper welding. Lewis Holding subsequently filed suit against Lexington, NTA, and Forsberg. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment for Defendants where (1) the insurance agreement plainly and unambiguously excluded coverage for damages due to mechanical failure; (2) Forsberg, who was not a party to the insurance contract, could not be held liable under the insurance policy; and (3) Defendants had reasonable bases for denying Lewis Holding’s claim. View "Lewis Holding Co., Inc. v. Forsberg Engerman Co." on Justia Law

Defendant, a contractor, and Plaintiff, a subcontractor, entered into a two subcontracts for part of a road work project. Plaintiff invoiced Defendant for the work under both contracts, but when Defendant failed to pay the full amount, Plaintiff filed suit for breach of contract damages and storage fees for Defendant’s equipment and materials. Defendant counterclaimed, alleging that Plaintiff had been overpaid on the contracts and had converted Defendant’s equipment. Defendant moved to have the matter removed to federal court and filed its counterclaim in that court. The case was subsequently remanded to state court, where Defendant filed its counterclaim. Plaintiff moved for summary judgment, claiming Defendant’s counterclaim was untimely. The district court granted the motion and dismissed the counterclaim. After a bench trial, judgment was entered in favor of Plaintiff. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate any basis to reverse the district court’s dismissal of its counterclaim on summary judgment; (2) alternatively, Defendant’s proposed counterclaim was moot; and (3) Plaintiff was entitled to attorney fees and costs. View "Motzko Co. USA, LLC v. A & D Oilfield Dozers, Inc." on Justia Law

Appellants decided to sell 850 acres of farmland but wanted to retain the mineral rights. Summit Title Services prepared the deeds for the sale, but he deeds did not reserve the minerals. Appellants were made aware of the omission at closing, insisted that the deeds be corrected, and were assured by Summit’s employee that the problem had been rectified. Six years later, Appellants learned that the minerals had been transferred with the land. Appellants filed suit against Summit, its general counsel Olen Snider, and Kuzma Success Realty, a brokerage firm involved in the transaction. The district court granted summary judgment for Appellees on all claims, concluding that Appellants failed to exercise due diligence to discover the error so as to extend the statute of limitation as a matter of law. The Supreme Court reversed the grant of summary judgment to Summit and Snider, concluding that there were genuine issues of material fact as to whether Appellants exercised due diligence to discover errors allegedly made by Summit and that Snider failed to present a prima facie case that he was entitled to summary judgment. View "Moats v. Prof'l Assistance, LLC " on Justia Law

In 2001, Appellant moved into Decedent’s home at Decedent’s request, where he lived and cared for Decedent until Decedent’s death in 2010. After Decedent’s death, Appellant filed a creditor’s claim against Decedent’s estate, seeking compensation for the care and services he provided. Defendants, the co-administrators of the estate, denied Appellant’s claim. Appellant subsequently brought an action against Defendants. The district court granted summary judgment to the estate. The Supreme Court affirmed, holding that the district court did not err in finding no question of material fact existed and that Appellant failed as a matter of law on his claims for implied-in-fact contract, promissory estoppel, and unjust enrichment. View "Symons v. Heaton" on Justia Law

After entering a construction contract with Appellants, Appellee filed a breach of contract and unjust enrichment action against Appellants. Appellants counterclaimed for breach of contract. The Supreme Court (1) affirmed the district court's judgment against Appellants with respect to Appellee's claims under the Prime Contract Change Order (PCCO) Nos. 1 and 2; (2) reversed the district court's order dismissing Appellee's claims relating to PCCO Nos. 3 and 4; and (3) affirmed the district court's dismissal of Appellants' counterclaims. Following remand, the district court (1) granted Appellee's motion to dismiss its remaining claims; and (2) dismissed all counterclaims of Appellants, declaring them to be moot. Appellants appealed, contending that the district court erred in dismissing their counterclaims and denying their request for costs and attorney's fees. The Supreme Court affirmed, holding that they district court did not abuse its discretion by (1) dismissing Appellant's counterclaims, as Appellee's dismissal of its claims rendered any contractual defense to the claims moot; and (2) declining to award costs and attorneys fees to Appellants, as Appellants could not be correctly classified as the prevailing party. View "Sterrett Props., LLC v. Big-D Signature Corp." on Justia Law

Gary Hopkins and Randal Burnett formed a LLC and financed the project with a small business administration (SBA) loan. Bank 1 loaned the remainder of the total project costs. Hopkins secured the SBA portion of the loan with third mortgages on his rental properties. Bank 2 subsequently acquired Bank 1. After Burnett bought Hopkins' membership in the LLC, Bank 2 released Hopkins from his loan. However, an agreement entered into by the parties did not mention the third mortgages on the property held by SBA. Burnett subsequently defaulted on his loan obligations, and Bank foreclosed on the mortgage covering the business property. Because Hopkins' third mortgages on his rental properties were not released by SBA, Hopkins was forced to continue to make the payments on the SBA loan. Hopkins and his wife (Plaintiffs) sued Bank 2, Burnett, and the LLC, arguing that, pursuant to the agreement, Bank 2 was supposed to remove Hopkins' liability and the mortgages held on his property. The district court granted summary judgment for Bank 2. The Supreme Court affirmed, holding that the terms of the contract between the parties were unambiguous, extrinsic evidence was not required to discern the parties' intent, and Bank 2 had abided by the terms of the contract. View "Hopkins v. Bank of the West" on Justia Law

Appellants purchased property that was subject to a Master Plan that restricted the use and development of the property. Appellants obtained title insurance from Insurer, but the policy did not mention the Master Plan. Appellants only later learned of the Master Plan when they were informed they were in violation of the Master Plan and faced substantial penalties if they failed to comply with the Plan. Appellants sued Insurer, claiming a breach of the terms of the title insurance policy, negligence, and bad faith. The district court granted summary judgment in favor of Insurer on all claims brought in Appellants' complaint. The Supreme Court affirmed, holding that the district court did not err in entering judgment in favor of Insurer. View "Sonnett v. First Am. Title Ins. Co." on Justia Law

Appellant sued his former employer (Employer) in district court, alleging claims for fraud and wrongful termination. Employer, however, had been sold to a foreign corporation (Corporation), which was not a resident of Wyoming. Corporation filed a motion to dismiss the case for improper venue and failure to state a claim upon which relief could be granted. The district court granted the motion on both grounds. The Supreme Court (1) affirmed the district court's dismissal for improper venue; but (2) vacated the district court's dismissal for failure to state a claim, holding that the court erred as a matter of law when it reached the merits of the case after determining that it had to be dismissed on venue grounds. Remanded for a dismissal without prejudice based upon improper venue. View "Bourke v. Grey Wolf Drilling Co., LP" on Justia Law