Justia Contracts Opinion Summaries

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

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

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

The Morningstars contracted to purchase a residential property from the Robisons, who intended to buy a nearby vacant lot and build a new house. When the lot they wished to buy was purchased by someone else, the Robisons failed to comply with the terms of the contract with the Morningstars. The Morningstars sought specific performance and monetary damages. The district court found the Robisons breached the contract, but denied the request for specific performance and awarded monetary damages.The Wyoming Supreme Court reversed. The district court erred in placing the burden on the Morningstars to prove monetary damages were an inadequate or impractical remedy and abused its discretion when it found specific performance was not an appropriate remedy. After finding only one of the special equities factors weighed in favor of the Robisons, the court essentially rewrote the contract to allow the Robisons to cancel because their preferred lot was unavailable. The Robisons admit they “had no legal recourse to cancel.” On remand, when determining if any monetary damages should be awarded in addition to specific performance, the court’s “guiding principle” should be to relate the contract back to August 2021, and place the Morningstars in as nearly the same position as they would have been in if the Robisons had not breached the contract. View "Morningstar v. Robison" on Justia Law

The Supreme Court reversed in part and affirmed in part the order of the district court granting summary judgment in favor of Ghidorzi Construction Company, LLC and dismissing the complaint brought by Primrose Retirement Communities, LLC and Gillette Retirement, LLC its local affiliate (together, Primrose), holding that the district court erred in granting summary judgment on Primrose's breach of contract claim.Primrose filed a complaint against Ghidorzi alleging negligence, breach of contract, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment in favor of Ghidorzi following a hearing. The Supreme Court reversed in part, holding (1) there were material questions of fact precluding summary judgment on the interpretation of the contract and whether Ghidorzi's actions contributed to Primrose's damages; and (2) the district court properly concluded that the contract language obviated any need to impose an implied covenant. View "Primrose Retirement Communities, LLC v. Ghidorzi Construction Co." on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Security State Bank (SSB) on Plaintiff's claims and SSB's breach of contract counterclaim, holding that there was no error.When Plaintiff defaulted on several agricultural loans she had obtained from SSB, SSB foreclosed on some of the collateral Plaintiff pledged to secure those loans. Plaintiff then brought this action, alleging, among other things, negligent lending and negligent advising. SSB counterclaimed, alleging, among other things, breach of contract. The district court granted summary judgment in favor of SSB on all claims. The Supreme Court affirmed, holding (1) this Court declines to recognize new causes of action for negligent lending or negligence advising; (2) there were no questions of material fact barring summary judgment on Plaintiff's breach of good faith and fair dealing claim; and (3) the district court did not err in finding that equitable defenses did not preclude entering summary judgment in favor of SSB on his counterclaim for breach of contract. View "Wilcox v. Security State Bank" on Justia Law

The Supreme Court affirmed the judgment of the district court confirming an arbitration award involving a breach of a lease agreement after ruling that the arbitrator's determinations were not manifest error and were within his authority, holding that the district court did not err in confirming the arbitration award.Mountain Business Center, LLC (MBC) won an arbitration award against Fork Road, LLC. On appeal, MBC made three arguments in support of his request that the Court reverse and vacate the arbitration award. The Supreme Court affirmed, holding (1) the arbitrator did not exceed his authority by determining all issues presented by the parties in their stipulated list; (2) the arbitrator's determination that MBC was not the prevailing party and therefore not entitled to attorney fees was not a manifest error of law; and (3) the arbitrator's determination the MBC was not entitled to the first-to-breach rule was not a manifest error of law. View "Mountain Business Center, LLC v. Ford Road, LLC" on Justia Law

The Supreme Court affirmed the judgment the district court denying TEP Rocky Mountain LLC's (TEP RM) motion to dismiss this action, granting summary judgment to Record TJ Ranch Limited Partnership (TJ Ranch) on several issues, and ruling that TEP RM had breached the parties' agreements, holding that there was no error.TJ Ranch brought this action seeking payment under a surface use and damage agreement governing oil and gas development and production of ranch lands. TEP RM filed a motion to dismiss for lack of personal jurisdiction, which the district court denied. The court ultimately concluded that TJ Ranch was entitled to payment. The Supreme Court affirmed, holding that the district court (1) correctly exercised personal jurisdiction over TEP RM; (2) did not clearly err in its findings; and (3) did not abuse its discretion in denying TEP RM's motions to stay. View "TEP Rocky Mountain LLC v. Record TJ Ranch Limited Partnership" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that PNS Stores, Inc. d/b/a Big Lots breached a lease with Capital City Properties, LLC and breached the implied covenant of good faith and fair dealing, holding that the district court did not err by finding that Big Lots breached the implied covenant of good faith and fair dealing.Capital City and Big Lots entered into a lease that required Capital City to deliver commercial property to Big Lots by a certain date. Capital City later filed a complaint against Big Lots alleging breach of contract and the implied covenant of good faith and fair dealing. Big Lots counterclaimed for breach of the lease. The district court found in favor of Capital City on both of its claims and awarded damages. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "PNS Stores, Inc. v. Capital City Properties, LLC" on Justia Law

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