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The Supreme Court reversed the judgment of the court of appeals in part and rendered judgment dismissing Plaintiff's claims that a governmental entity breached a contractual promise to make a good faith effort to obtain authorization for a higher payment than the parties' written contract required the entity to make, holding that governmental immunity applied and that chapter 271 of the Texas Local Government Code did not waive the entity's immunity. Vizant Technologies sued the Dallas-Fort Worth International Airport Board for, inter alia, breach of contract, alleging in part that the Board failed to make a promised good-faith effort to authorize increased compensation than that set forth in the parties' contract. The Board filed a plea to the jurisdiction, asserting that governmental immunity barred Vizant's claims. The trial court denied the plea. The court of appeals affirmed the trial court's denial of the Board's plea against Vizant's breach of contract claim, holding that, while governmental immunity applied, chapter 271 of the Texas Local Government Code waived the Board's immunity against that claim. The Supreme Court reversed, holding that governmental immunity barred all of Vizant's claims against the Board and that chapter 271 did not waive that immunity. View "Dallas/Fort Worth International Airport Board v. Vizant Technologies, LLC" on Justia Law

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In this breach of contract case filed by Employees against Employer, the Supreme Court reversed the judgment of the court of appeals affirming the trial court and rendered judgment that Employees taking nothing, holding that there was not legally sufficient evidence that would have allowed reasonable, fair-minded people to find that Employer and Employees impliedly agreed to change the compensation of Employees from payment based on hours worked to fixed annual salaries. Employees were four nurses who worked for McAllen Hospitals, L.P. (Employer). Employees were paid based on the hours they worked. In their lawsuit against Employer, Employees alleging that Employer had promised to pay them annual salaries and had breached that agreement. The jury found that the parties had agreed Employees would receive a fixed amount of pay and that Employer breached that agreement. The court of appeals affirmed. The Supreme Court reversed, holding that the evidence was legally insufficient to support the jury's finding that Employer agreed to pay Employees a fixed salary. View "McAllen Hospitals, LP v. Lopez" on Justia Law

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The Supreme Court affirmed the district court's grant of summary judgment dismissing this action filed by a public employee union seeking to enforce a collective bargaining agreement entered into with the Iowa Board of Regents, holding that the Public Employment Relations Board (PERB) acted within its statutory authority in promulgating Iowa Admin. Code R. 621-6.5(3), which has the force of law, and that the district court correctly applied rule 621-6.5(3) to hold the parties had no enforceable collective bargaining agreement (CBA) without the Board's vote to ratify it. The Board moved for summary judgment on the union's action to enforce the CBA, relying on rule 621-6.5, which requires the Board to meet to vote to accept a tentative voluntary agreement ratified by the union before the contract becomes effective. The union argued that the agency rule was invalid because it imposed a ratification requirement not included in Iowa Code 20.17(4). The district court upheld the validity of the agency rule and dismissed the union's enforcement action. The Supreme Court affirmed, holding (1) rule 621-6.5(3) is valid; and (2) therefore, no enforceable agreement was reached without the requisite vote by the Board to approve the CBA. View "Service Employees International Union, Local 199 v. State" on Justia Law

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In this action brought by Lisa Warrington bringing claims for breach of contract, breach of the covenant of good faith and fair dealing, and promissory estoppel the Supreme Court affirmed the district court's order granting partial summary judgment to Great Falls Clinic, LLP and denied the Clinic's cross appeal, holding that the district court did not err. Specifically, the Court held that the district court (1) did not err by granting partial summary judgment to the Clinic on Warrington's tort claim for breach of the covenant of good faith and fair dealing; (2) did not commit reversible error by admitting evidence of the Clinic's liability and Warrington's emotional distress; (3) did not err by denying the Clinic's motion for judgment as a matter of law regarding Warrington's damages; and (4) did not err by failing to rule and instruct the jury that the contract at issue was for a one-year term pursuant to Mont. Code Ann. 39-2-602(1). View "Warrington v. Great Falls Clinic, LLP" on Justia Law

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David Kosmann appealed a district court judgment relating to a dispute that arose from the sale of real property. He claimed the district court erred in enforcing an oral settlement agreement reached in mediation between Kosmann, Kevin Dinius, and Dinius & Associates, PLLC (collectively “Dinius”). Kosmann also argued the trial court erred in: (1) awarding attorney fees to Dinius as a sanction against Kosmann and his attorney; (2) declining to impose sanctions against Dinius and his attorney; and (3) striking an untimely memorandum and declaration in support of his motion to reconsider. After review of the trial court record, the Idaho Supreme Court affirmed in part and reversed in part. The Supreme Court determined the district court did not err in enforcing the settlement agreement; the court also did not err in declining to impose sanctions against Dinius on ethics violations. However, the Supreme Court determined the district court abused its discretion in imposing I.R.C.P. 11 sanctions against Kossman and his counsel: the district court did not act consistently with the applicable legal standard for imposing sanctions pursuant to I.R.C.P. 11(b). The Supreme Court declined to address all other issues Kossman raised, and determined he was not entitled to attorney fees on appeal. "The record in this case is so tarnished with questionable conduct that it has presented this Court with a vexing ethical and legal dilemma. While we are gravely concerned over the potential ethical lapses which allegedly occurred during the mediation of this matter, there are no findings in the record concerning these matters. Therefore, as the trial court determined, we will leave to the Idaho State Bar, if properly called upon, the responsibility to investigate this matter further and make the necessary findings and conclusions as to the ethical issues presented." View "Kosmann v. Dinius" on Justia Law

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After plaintiffs filed suit against the Association and property manager for breach of contract and negligence, the trial court granted a nonsuit. Plaintiffs settled with the property manager but appealed against the association. The Court of Appeal reversed the trial court's grant of a nonsuit on the breach of contract claim where reasonable jurors could have concluded a total failure to maintain common areas breached a promise to keep these areas in first class condition and a jury could also find that buildings need maintenance to remain in first class condition. Furthermore, the trial court erred by adding oral reasoning beyond the contents of the nonsuit motion, and neither the motion nor the trial court's rationale challenged the idea that covenants, conditions, and restrictions comprise a contract between the association and individual owners. Nor did the motion or rationale hint at the rule of deference governing owner suits against homeowner associations. The court affirmed the nonsuit tort judgment and held that the association had no independent duty as to the pipes and roof arising from tort law. View "Sands v. Walnut Gardens Condominium Assn." on Justia Law

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Two debtor limited liability companies (LLCs) executed security agreements in favor of two creditor LLCs, giving the creditor LLCs security interests in three airplanes. Disputes arose when the creditor LLCs, considering the debtor LLCs in default, took possession of two airplanes and removed and retained parts of a third airplane. After a bench trial the superior court entered judgment against the debtor LLCs and an individual associated with both of them. The debtor LLCs and the individual appealed, raising issues about default, seizure of collateral, and post-seizure notice; the individual also questioned the judgment against him personally. The Alaska Supreme Court affirmed the superior court’s finding that failure to give Knik Aircraft Leasing notice of default prior to repossession of the Cessnas was harmless; the Court also affirmed the superior court’s interpretation of the text messages between Helmericks and the individual, Brett Crowley. The Court reversed the superior court’s decision that Northern Aviation’s failure to provide notice of disposition of the Cessnas was harmless. The Court vacated the superior court’s decisions about the repossession of the Mooney, its entry of judgment on the Mooney-secured loan, and its entry of judgment against Crowley in his individual capacity. The matter was thereafter remanded to the superior court for further proceedings. View "Crowley, et al. v Northern Aviation, LLC, et al." on Justia Law

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Putnam County Memorial Hospital ("Putnam") appealed a circuit court denial of its motion to set aside a default judgment entered in favor of TruBridge, LLC ("TruBridge"), and Evident, LLC ("Evident"). In September 2015, Putnam entered into a "Master Services Agreement" with TruBridge ("the MSA agreement") and a license and support agreement with Evident ("the LSA agreement"). In the MSA agreement, TruBridge agreed to provide accounts-receivable management services for Putnam for five years. The MSA agreement provided that TruBridge would receive 5.65 percent of the "cash collections," as that term is defined in the MSA agreement, to be paid monthly, for its account and billing services. In the LSA agreement, Evident agreed to provide Putnam with Evident's electronic health-records system as well as maintenance and support for that system. According to Putnam, starting in 2016, Putnam entered into a series of agreements with Hospital Partners, Inc. ("HPI"), in which HPI agreed to manage and control the operations of the hospital and its facilities. TruBridge and Evident alleged that at that time, Putnam began entering patient information and billing services through a different computer system than the one provided by Evident pursuant to the LSA agreement and used by TruBridge for accounts receivable pursuant to the MSA agreement. When a TruBridge manager contacted Putnam to inquire about this drop in new-patient admissions into their system, Putnam claimed to have almost no new patients and that it was barely surviving. TruBridge and Evident alleged Putnam was deliberately false and that Putnam was, in fact, simply entering new patients into a different system. Putnam did not enter an appearance in the lawsuit brought by TruBridge and Evident for breach of contract. The circuit court entered a default judgment. Putnam's motion to set aside the judgment was denied. The Alabama Supreme Court concluded Putnam met its evidentiary threshold to trigger the statutory requirement the circuit court reconsider its motion to set aside and for reconsideration relating to the default judgment. Therefore, the Court reversed the circuit court and remanded for further proceedings. View "Putnam County Memorial Hospital v. TruBridge, LLC, and Evident, LLC" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals finding that Petitioner waived the argument that his contractual waiver of the statute of limitations was void as against public policy, holding that the court of appeals erred in declining to reach Petitioner's argument but that, when the enforceable portions of Petitioner's contractual waiver were applied, limitations did not bar Respondent's suit against Petitioner. Petitioner guaranteed a loan secured by real property. When the borrower defaulted, Respondent Wells Fargo Bank, N.A.'s successor foreclosed on the real property securing the loan. After purchasing property at a foreclosure sale Respondent sued Petitioner to recover the deficiency. Petitioner moved for summary judgment, arguing that Respondent's claim was barred by the two-year statute of limitations for deficiency claims. Respondent moved for partial summary judgment on the grounds that Petitioner waived Tex. Prop. Code 51.003's statute of limitations when he signed the guaranty agreement. The trial court granted summary judgment for Respondent. The court of appeals affirmed, holding that Petitioner waived his public policy argument. The Supreme Court affirmed, holding (1) Petitioner contractually waived the two-year statute of limitations and that a four-year statute of limitations applied to Respondent's claims; and (2) because Respondent sued Petitioner within that four-year period, limitations did not bar the suit. View "Godoy v. Wells Fargo Bank, N.A." on Justia Law

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In this contract dispute stemming from a seller-financed real estate transaction, the Supreme Court affirmed in part and reversed in part the judgment of the district court, holding primarily that the district court was not precluded by the mandate rule from determining that the promissory note did not require the buyers to pay any incurred late fee amounts to bring note current because the court construed an ambiguity in the note against the defendants, as drafters, without first considering extrinsic evidence. The buyers purchased the real estate with a promissory note that required them to make an installment payment each month and a final balloon payment. The note applied a ten percent base interest rate on the unpaid principal and established consequences if the buyers missed an installment payment, including a late fee and bump up in the base interest rate until the note was brought current. The buyers made the installment payments but disagreed over the amount owing the final balloon payment, leading to litigation. The Supreme Court remanded the case for a new determination after the court considers relevant extrinsic evidence and held that the district court did not clearly err in determining that extrinsic evidence showed that the parties did not intent the note's late fee to apply to the final payment. View "Brady v. Park" on Justia Law