Justia Contracts Opinion Summaries
Robertson v. Intratek Computer, Inc.
A federal whistleblower statute, 41 U.S.C. 4712, does not render unenforceable an arbitration agreement between plaintiff and his former employer, Intratek. The Fifth Circuit held that the district court correctly enforced the arbitration agreement between plaintiff and Intratek. However, the court held that the district court erred in compelling arbitration of claims not covered by that agreement. Finally, the court held that the district court did not abuse its discretion by denying plaintiff's motion to amend the complaint. Therefore, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Robertson v. Intratek Computer, Inc." on Justia Law
Slota v. Imhoff
The Supreme Court affirmed the order of the circuit court granting Defendants' motion for judgment on the pleadings and dismissing Plaintiff's fraud and deceit claims, holding that the claims were time barred.Plaintiff sued a law firm and its attorneys, alleging legal malpractice, fraud and deceit related to their representation of Plaintiff on criminal charges. The circuit court granted judgment on the pleadings for Defendants, concluding that the claims were time-barred by the three-year statute of repose for legal malpractice under S.D. Codified Laws 15-2-14.2. Plaintiff appealed, arguing that the circuit court erred in dismissing the fraud and deceit claims because those claims were subject to a six-year statute of limitations. The Supreme Court affirmed, holding (1) Plaintiff's fraud and deceit claims were subsumed within his malpractice claim; and (2) therefore, all of Plaintiff's claims were precluded under the repose statute. View "Slota v. Imhoff" on Justia Law
Compania Embotelladora Del Pacifico, S.A. v. Pepsi Cola Co.
This appeal stems from a contract dispute between PepsiCo and one of its independent Peruvian bottlers, CEPSA. After PepsiCo terminated its contract with CEPSA, CEPSA filed suit in district court alleging, inter alia, breach of contract claims based on wrongful termination and PepsiCo's alleged failure to protect CEPSA's rights as the exclusive bottler and distributor of PepsiCo products in specified areas of Peru.The Second Circuit affirmed the district court's judgment in favor of PepsiCo and held that the contract was terminable at will and that PepsiCo had no affirmative duty under the contract to protect CEPSA against the alleged harm to its exclusive rights. In this case, the court applied the New York common law of contracts, looked within the four corners of the contract, and concluded that the Exclusive Bottler Appointment (EBA) was terminable at will and that PepsiCo had no duty to police or prevent transshipment. The court considered CEPSA's remaining arguments on appeal and concluded that they are without merit. View "Compania Embotelladora Del Pacifico, S.A. v. Pepsi Cola Co." on Justia Law
Massey et al. v. Duke Builders, Inc.
Property owners and the contractors they hired to build a house had a dispute. The Georgia Supreme Court granted the owners' request for review to consider: (1) whether anticipated profits could be included in a materialmen’s lien; and (2) if so, whether the improper inclusion of such profits rendered the entire lien void. Because the Court of Appeals correctly held that anticipated profits could not be included in a lien and that their inclusion does not invalidate the entire lien, the Supreme Court affirmed. View "Massey et al. v. Duke Builders, Inc." on Justia Law
Mantle v. North Star Energy & Construction LLC
The Supreme Court affirmed the decision of the district court using a judgment against Alexander Mantle to set off judgments Alexander and Majorie Mantle had against Ray and Gary Garland and failing to recognize the Mantles' right to the proceeds from a settlement of a third-party action against Karl Killmer and Killmer & Associates (collectively, Killmer), holding that the district court did not err.Specifically, the Supreme Court held (1) Ray and Gary were entitled to use the assigned portions of the judgment against Alexander to satisfy the judgments the Mantles had against them for fraudulent transfers; and (2) the district court did not have jurisdiction to the portion of the Killmer settlement funds not deposited with the district court. View "Mantle v. North Star Energy & Construction LLC" on Justia Law
Mann Agency, LLC v. Mississippi Department of Public Safety
After the Mississippi Department of Public Safety (MDPS) reinterpreted a provision in a contract between it and the Mann Agency, LLC, the MDPS refused to pay more than $700,000 in invoices submitted by the Mann Agency. The Mann Agency filed suit against the MDPS for breach of contract. The trial court dismissed each party’s breach-of-contract claim, found that the case involved a bona fide dispute, and denied the Mann Agency’s claim for interest and attorneys’ fees. The Mann Agency appealed the trial court’s decision to deny its claim for interest and attorneys’ fees, arguing that the MDPS acted in bad faith. The MDPS cross-appealed, arguing the trial court erred by dismissing as moot its breach-of-contract claim. Finding no reversible error, the Mississippi Supreme Court affirmed the trial court's decisions. View "Mann Agency, LLC v. Mississippi Department of Public Safety" on Justia Law
MTSUN, LLC v. Montana Department of Public Service Regulation
The Supreme Court overruled the decision of the Public Service Commission (PSC) rejecting a proposed development of an eighty-megawatt solar energy facility near Billings, Montana, holding that the PSC violated the requirements of the federal Public Utility Regulatory Policies Act (PURPA) and state law precluding discrimination against solar energy projects.The district court reversed and remanded the PSC's order setting terms and conditions of MTSUN, LLC's proposed eighty megawatt solar project based on findings of violations of due process, PURPA, and Montana's mini-PURPA. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that the PSC's determinations were arbitrary and unlawful; and (2) relied on record evidence in determining the existence of a legally-enforceable agreement and the avoided-cost rates. View "MTSUN, LLC v. Montana Department of Public Service Regulation" on Justia Law
Mentis Sciences, Inc. v. Pittsburgh Networks, LLC
Plaintiff Mentis Sciences, Inc. appealed a superior court order dismissing its claims for damages representing the cost of recreating lost data and lost business and negligence against defendant Pittsburgh Networks, LLC. Plaintiff was an engineering firm that, among other things, designed, developed, and tested advanced composite materials for United States Department of Defense customers. Since entering this sector in 1996, plaintiff acquired “a vast amount of valuable data that was utilized in its operations.” In 2010, the defendant began providing the plaintiff with technological support or “IT” services. In August 2014, defendant notified plaintiff that a drive in one of its servers had failed and would need to be replaced; a controller malfunctioned, causing the corruption of some of plaintiff’s data. Defendant attempted to recover the corrupted data; however, the data was permanently lost because defendant had failed to properly back it up. Plaintiff filed suit against defendant, alleging breach of contract and negligence. In its complaint, plaintiff alleged that the lost data “represents valuable intellectual property compiled over many years and is of daily critical use in [the plaintiff’s] business.” Further, plaintiff alleged that, as a result of the data loss, it was required to conduct “massively expensive” testing in order to recreate the data and that, without the lost data, it was “unable to bid or participate in various projects worth potentially millions of dollars.” Plaintiff argued on appeal of the dismissal of its suit that the trial court erred by: (1) concluding that the damages representing the cost of recreating lost data and lost business were consequential; (2) concluding that the limitation of liability clause in the parties’ contract is enforceable; and (3) dismissing its claim for negligence. The New Hampshire Supreme Court affirmed because the damages sought by plaintiff were consequential and the limitation of liability clause in the parties' contract precluded plaintiff from recovering consequential damages. The Court also concluded the economic loss doctrine barred plaintiff’s negligence claim. View "Mentis Sciences, Inc. v. Pittsburgh Networks, LLC" on Justia Law
Flanzman v. Jenny Craig, Inc.
Jenny Craig, Inc. hired Marilyn Flanzman to work as a weight maintenance counselor in 1991. In May 2011, Flanzman signed a document entitled “Arbitration Agreement” in connection with her employment. In February 2017, when the dispute that led to this appeal arose, Flanzman was eighty-two years old. Flanzman’s managers informed her that her hours would be reduced from thirty-five to nineteen hours per week. In April 2017, Flanzman’s managers further reduced her hours to approximately thirteen hours per week. In June 2017, they reduced her hours to three hours per week, at which point she left her employment. Flanzman brought suit, asserting claims for age discrimination, constructive discharge, discriminatory discharge, and harassment. Relying on the Agreement, defendants moved to dismiss the complaint and to compel arbitration. Defendants contended that California law governed the Agreement and that the Agreement was enforceable. The trial court granted the motion to dismiss and ordered the parties to arbitrate Flanzman’s claims. It held that California law governed the arbitration and that the proper forum was assumed to be California. Finding no reversible error, the New Jersey Supreme Court affirmed the trial court's judgment. View "Flanzman v. Jenny Craig, Inc." on Justia Law
Franklin v. Regions Bank
After plaintiffs contracted with Regions Bank for it to manage, as their agent, their mineral interests in a large tract of land, Regions signed a lease extension with a third party, intending to extend the lease for only a small part of the property. However, the lease was unlimited and applied to the entire tract of land. Region's unintentional mistake cost plaintiffs tens of millions of dollars.The Fifth Circuit reversed the district court's dismissal of plaintiffs' action for breach of contract against Regions, holding that Louisiana's ten year statute of limitations period for contract claims applies to plaintiffs' suit. In this case, plaintiffs alleged that Regions breached their contracts by acting negligently. The court stated that, under Louisiana law, they had the choice to sue Regions for this alleged breach in tort or in contract. Because plaintiffs chose contract, their claim is subject to the ten year statute of limitations. Accordingly, the court remanded for further proceedings. View "Franklin v. Regions Bank" on Justia Law