Justia Contracts Opinion Summaries

Jackman Construction, Inc. (Jackman) was the successful bidder on a project to install new water lines and a pump station for the City of Green River. Rock Springs Winnelson Co. (Winnelson) supplied materials for the project. Jackman eventually stopped paying Winnelson’s invoices, and Winnelson refused to provide any more materials. Winnelson filed suit against Jackman for its failure to pay invoices totaling $21,705, which included principal and service charges. Jackman counterclaimed for, inter alia, breach of contract and promissory estoppel. The district court granted judgment in favor of Winnelson on the outstanding principal, denied Winnelson’s claim for unpaid service charges, and denied Jackman’s counterclaims. The Supreme Court affirmed, holding (1) the district court erred in refusing to accept the parties’ stipulation as to the amount Jackman paid Winnelson, but the error was harmless; (2) the district court did not err in the remainder of its judgment; and (3) sanctions were not warranted. View "Jackman Construction, Inc. v. Rock Springs Winnelson Co." on Justia Law

Plaintiffs, the purchasers of a health claims administration company, brought a breach of contract action against Defendant, the seller. After learning that they had not acquired all of the assets that contracted to purchase, Plaintiffs continued to operate the business for the next eighteen months. Only then did they stop making payments on the promissory note and then file this action. Defendant counterclaimed for breach of contract. Plaintiffs raised the affirmative defense that Defendant was first to breach the contract and that Plaintiffs were therefore excused from performing their contractual duties. The district court entered judgment in favor of Defendant. The Supreme Court affirmed, holding that Plaintiffs’ conduct after learning of Defendant’s alleged breach precluded it from asserting a prior breach as a defense to Plaintiffs’ breach-of-contract claim. View "Maverick Benefit Advisors, LLC v. Bostrom" on Justia Law

Jason Thornock requested that PacifiCorp provide electric service to an irrigation pivot on his property using a particular easement. PacifiCorp did not utilize the easement that Thornock suggested but did provide electric service to the pivot using a different route under the terms of a second contract the parties entered into after the original contract. When PacifiCorp did not provide power under the easement provided for in the first contract, Thornock filed a complaint against PacifiCorp based on the alleged breach of the first contract. The district court granted summary judgment in favor of PacifiCorp. The Supreme Court affirmed, holding that the first contract between the parties had been superseded and that PacifiCorp was not required to perform under the provisions of that agreement. View "Thornock v. PacifiCorp" on Justia Law

Appellants, the owners of a tract of land in the Riva Ridge subdivision, submitted their plans to build a home and writer’s studio to the Riva Ridge Owners Association’s Site Committee. The Site Committee rejected the plans on the basis that some of Appellants’ home would be visible from some locations in other homes. Appellants filed a complaint against the Association and others (collectively, Appellees) alleging several causes of action. Appellants filed a separate complaint requesting a determination of the term “principal residence site” in the covenants. The district court granted summary judgment for Appellees on several issues. After a trial, the district court interpreted the phrase “principal residence site” in a way that required complete invisibility between the homes in the subdivision. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) erred in its interpretation of the phrase “principal residence,” as the covenants only require that a principal residence be invisible only from a precise area of land on each tract; (2) erred in granting summary judgment on Appellants’ breach of contract and bad faith claims; and (3) properly determined that Appellants must seek permission from the Site Committee before planting any trees on their tract. View "Felix Felicis, LLC v. Riva Ridge Owners Ass’n" on Justia Law

Jeff Lokey and Mike Irwin were business partners in two Wyoming businesses. After the parties dissolved their shared business interests, Irwin filed suit against Lokey, alleging that Lokey had materially breached the terms of the agreement. When Lokey did not timely file an answer the district court entered a default judgment against Lokey that included a provision allowing the parties ten days to file objections to the judgment. Lokey filed an objection, which the district court denied. Lokey appealed, challenging the court’s denial of his objections. The Supreme Court dismissed the appeal, holding (1) the Court lacked jurisdiction to entertain the appeal because Lokey did not timely appeal an appealable order; but (2) the Court had jurisdiction to award, and Irwin was entitled to recover, reasonable attorney fees incurred as a result of this appeal. View "Lokey v. Irwin" on Justia Law

Pennaco Energy Inc. acquired mineral leases beneath a surface estate owned by Brett Sorenson, Trustee of the Brett L. Sorenson Trust. A surface damage and use agreement between the parties granted Pennaco access to and use of the land for exploration and production of minerals, and, in return, required Pennaco to pay for the damage to and use of the surface estate, and to reclaim the land once operations ended. When Pennaco refused to perform its obligations under the contract, Soreson brought this lawsuit. The jury rendered a verdict finding that Sorenson suffered more than $1 million in damages. The district court entered judgment on the jury’s verdict and also awarded Sorenson costs and attorney fees. The Supreme Court affirmed, holding that the district court did not err by (1) ruling that Pennaco remained liable under the surface damage and use agreement after assignment, and (2) using a 2.5 multiplier to enhance the lodestar amount in awarding attorney fees. View "Pennaco Energy, Inc. v. Sorenson" on Justia Law

Automation & Electronics, Inc. (A&E) and Consolidated Electric Distributors, Inc. (CE) sued for Red Desert Reclamation, LLC for amounts due on their respective contracts. Pursuant to a stipulation between A&E and Red Desert, the district court entered judgment in favor of A&E. CE was later voluntarily dismissed from the case. A&E subsequently filed a motion for leave to amend its complaint to add CSC Group Holdings, LLC and Cate Street Capital, Inc. as defendants and to add alter ego and fraudulent conveyance claims. The district court granted the motion to amend. The district court then entered two default judgments in favor of A&E making CSC, Cate Street and Red Desert jointly and severally liable on Red Desert’s debt to A&E and setting aside as fraudulent a mortgage granted by Red Desert to CSC, thereby allowing A&E to execute on real property to recover on its judgment against Red Desert. The Supreme Court affirmed, holding that the district court did not lose subject matter jurisdiction over A&E’s motion to amend its complaint after signing off on the stipulated judgment in its favor because A&E was allowed to amend its complaint before CE was voluntarily dismissed from the action. View "CSC Group Holdings, LLC v. Automation & Electronics, Inc." on Justia Law

At the heart of these three consolidated appeals was Sky Harbor’s alleged failure to pay rent to the Cheyenne Regional Airport and to leave the Airport premises. Sky Harbor argued that the district court lacked subject matter jurisdiction to decide any of the cases now on appeal. The district court generally ruled in favor of the Airport in all three cases. The Supreme Court affirmed, holding (1) the district and circuit courts did not lack subject matter jurisdiction in the three combined appeals; and (2) the judgments were entered in accordance with the law. View "Sky Harbor Air Serv., Inc. v. Cheyenne Reg’l Airport Bd." on Justia Law

Leon and Brenda Rogers purchased a home from Jeffrey Wright. The Rogers subsequently discovered several defects in the home and sued Wright, JWright Development, LLC, and JWright Companies, Inc. (collectively, the JWright defendants), alleging breach of contract, negligence, breach of warranty, and negligent and intentional misrepresentation. The district court granted summary judgment in favor of the JWright defendants. The Supreme Court reversed the district court’s order on the negligence claim but otherwise affirmed, holding (1) issues of material fact existed regarding whether the builder of the Rogers’ home breached its legal duty to build the home in a reasonable and workmanlike manner; and (2) the district court properly granted summary judgment in favor of the JWright defendants on the remainder of the Rogers’ claims. View "Rogers v. Wright" on Justia Law

Pennaco Energy, Inc. obtained oil and gas leases and made contracts with the surface landowners, who were predecessors of Appellees. The contracts granted Pennaco use of the landowners’ land during exploration and production under the mineral leases. After several years, Pennaco assigned its interest in its coal bed methane operation to CEP-M purchase, LLC, which re-assigned those interests to High Plains Gas, Inc. After the assignment, neither Pennaco nor the assignees made any required payments under the assignments, nor did they reclaim any of the land, as required under the agreements. Appellees sued Pennaco for breach of the agreements. The district court granted summary judgment in favor of Appellees. Pennaco appealed, arguing that the district court erred in concluding that Pennaco remained liable under the agreements even after the assignment. The Supreme Court affirmed, holding that because the agreements contained indications that Pennaco’s contractual obligations continued even after assignment and because there was no express clause that terminated Pennaco’s obligations upon assigning the agreements to a third party, Pennaco remained liable to Appellees to perform the covenants in the event its assignee defaulted. View "Pennaco Energy, Inc. v. KD Co., LLC" on Justia Law