Justia Contracts Opinion Summaries

Jeff Good and Harry’s Dairy entered into a contract providing that Harry’s Dairy would purchase 3,000 tons of Good’s hay. Harry’s Dairy paid for and hauled approximately 1,000 tons of hay over a period of approximately eight weeks, but did not always pay for the hay before hauling it and at one point went several weeks without hauling hay. After Harry’s Dairy went a month without hauling additional hay, Good demanded that Harry’s Dairy begin paying for and hauling the remaining hay. Harry’s Dairy responded that it had encountered mold in some of the hay, but would be willing to pay for and haul non-moldy hay at the contract price. Good then sold the remaining hay for a substantially lower price than he would have received under the contract and filed a complaint against Harry’s Dairy alleging breach of contract. Harry’s Dairy counterclaimed for violation of implied and express warranties and breach of contract. The district court granted summary judgment in favor of Good on all claims, and a jury ultimately awarded Good $144,000 in damages. Harry’s Dairy appealed, arguing that there were several genuine issues of material fact precluding summary judgment, that the jury verdict was not supported by substantial and competent evidence, and that the district court erred in awarding attorney fees, costs, and prejudgment interest to Good. Finding only that the district court erred in granting summary judgment on the implied warranty of merchantability counterclaim, the Idaho Supreme Court reversed as to that issue, affirmed as to all others, and remanded for further proceedings. View "Good v. Harry's Dairy" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiffs' breach of contract action against Defendant, their insurer, holding that the district court properly dismissed for failure to state a claim Plaintiffs' claim that Defendant failed to defend and indemnify them in a state court action.Newton Covenant Church (NCC) was comprised of members of the Newton Presbyterian Church (NPC) who withdrew from the Presbyterian Church (USA) and affiliated with a non-Presbyterian organization. NPC and the Presbytery of Boston sued the NCC in the state superior court seeking, among other things, a declaratory judgment that NPC owned church property at 75 Vernon Street in Newton, Massachusetts. NCC submitted a notice to the Great American Insurance Company (GAIC) requesting a defense in the state court action under a Director and Officers insurance policy. GAIC denied coverage on the grounds that the named insured under the policy was NPC, not NCC. After the parties reached a settlement NCC and its individual officers (collectively, Plaintiffs) brought this action against GAIC for breach of contract. The district court dismissed the complaint. The First Circuit affirmed, holding that Plaintiffs' allegations were not reasonably susceptible of an interpretation that would state a claim covered under the policy. View "Newton Covenant Church v. Great American Insurance Co." on Justia Law

The Supreme Court affirmed the order of the circuit court denying Petitioners' motion to compel arbitration of Respondents' claims against them, holding that a merger clause in the retail sales installment contract (RISC) between the parties served to supplant the arbitration agreement contained in the previously-executed credit application.Respondents purchased a new truck from Petitioners. Respondents first executed a credit application that contained an arbitration provision. Thereafter, the parties executed the RSIC, which did not contain an arbitration clause. After Respondents defaulted on their loan Petitioners began collection efforts. Respondents filed this complaint asserting that Petitioners harassed them by phone even after being advised they were represented by counsel. Petitioners moved to compel arbitration based on the arbitration provision contained in the credit application. The circuit court denied the motion. The Supreme Court affirmed, holding that the arbitration provisions in the credit application did not survive the merger clause of the RISC, thereby nullifying Respondents' obligation to arbitrate their claims against Petitioners. View "TD Auto Finance LLC v. Reynolds" on Justia Law

United owns a fleet of ambulances. In 2016, Stofko was driving his car when a United ambulance crashed into it; Stofko’s injuries were fatal. United was insured by Markel but the particular ambulance that crashed was not listed on the policy. Rau, the representative of Stofko’s estate, argued that it was nevertheless covered by the policy because before the crash United sent Markel’s agent, Insurance Service Center, an email requesting that the vehicle be added to the policy. The Center denied seeing the email and United acknowledged that it had not received a response as was customary. Markel argued that even if United had sent an email, it never endorsed the change, which the policy requires, and has no duty to indemnify United or the driver and no duty to defend in Rau’s suit. The Seventh Circuit affirmed summary judgment in favor of Markel. It is not necessary to resolve what happened to the email request to add the vehicle to the policy; under Indiana law courts may not rewrite an insurance contract. Neither Center nor Markel accepted or responded in any way to United’s request, so the ambulance was not covered. View "Markel Insurance Co. v. Rau" on Justia Law

In this case involving the extent to which a judgment debtor's rights of action are subject to execution to satisfy a judgment the Supreme Court held that a judgment debtor's claims that are unassignable cannot be purchased at an execution sale.Respondents filed a motion to substitute themselves in place of Appellants and to voluntarily dismiss this appeal because they purchased Appellants' rights and interests in the underlying action at a judgment execution sale. The Supreme Court denied the motion in part and granted the motion in part, holding (1) because Appellants' claims for fraud and elder exploitation were personal in nature, they were not assignable and not subject to execution at a sheriff's sale, and therefore, Respondents did not purchase the rights to these claims at the execution sale; and (2) Appellants' claims of negligent misrepresentation and breach of contract were assignable and subject to execution, and therefore, this appeal is dismissed as to these claims. View "Reynolds v. Tufenkjian" on Justia Law

The Supreme Judicial Court vacated in part and affirmed in part the lower court's judgment in favor of Plaintiffs and against Compass Harbor Village Condominium Association and Compass Harbor Village, LLC (collectively, Compass Harbor), holding that the court erred in ordering specific performance and entering judgment for Plaintiffs on the claim brought pursuant to the Maine Unfair Trade Practices Act (UTPA), Me. Rev. Stat. 5, 205-A to 2014.Plaintiffs brought suit alleging that Compass Harbor's actions with respect to maintenance and governance of the Association caused their units to lose value. The lower court found that Compass Harbor breached the contracts between it and Plaintiffs, the LLC violated its fiduciary duties to Plaintiffs, and Compass Harbor violated section 207 of the UTPA. The court awarded damages to Plaintiffs and entered an order of specific performance requiring Compass Harbor to abide by its contractual and fiduciary duties in the future. The Supreme Judicial Court vacated the judgment in part, holding (1) the UTPA did not apply in this case; (2) the court did not clearly err in calculating damages; and (3) the court went beyond its discretion in entering an order that would involve the court in continuous supervision of Compass Harbor's performance over an indefinite period. View "Brown v. Compass Harbor Village Condominium Ass'n" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellants' motion to compel arbitration pursuant to the arbitration agreement contained in the parties' installment-sales contract, holding that the contract was supported by mutual obligations and plainly stated that Appellants did not waive arbitration by obtaining a monetary judgment in the small claims division of district court.Appellees purchased a vehicle with an installment-sales contract but failed to make their scheduled payments. Appellees voluntarily surrendered the vehicle, the vehicle was sold, and Appellees' account was credited. Appellants filed a complaint in the small claims division seeking payment for the remaining balance, and the district court entered judgment against Appellees. Appellees appealed, counterclaimed based on usury and Uniform Commercial Code violations, and sought class certification. Appellants sought to compel arbitration. The circuit court denied the motion, concluding that the arbitration agreement at issue lacked mutuality of obligation and that Appellants waived the right to arbitrate by first proceeding in district court. The Supreme Court reversed, holding (1) the arbitration agreement was valid; and (2) Appellants did not waive arbitration by first seeking monetary relief in district court. View "Jorja Trading, Inc. v. Willis" on Justia Law

In this dispute over the sale proceeds from an auction of cattle the Supreme Court affirmed in part and reversed in part the entry of partial summary judgment on Plaintiff's claim for the sale proceeds, holding that Defendant had a right to pursue his disputed claim for an additional $12,500.Pursuant to the terms of a sales agreement Plaintiff purchased cows and calves from Defendant. The agreement required Plaintiff to pay for the cattle in installments, with Defendant retaining a security interest in the cattle. After Plaintiff sold the remaining cows purchased from Defendant at auction Plaintiff calculated a payoff to Defendant to satisfy the balance of the agreement, with a remaining balance paid to Plaintiff. When Defendant refused to allow any of the sale proceeds to be released from the auction barn Plaintiff brought this action. The circuit court granted Plaintiff's motion for partial summary judgment on its claim for the sale proceeds and entered judgment against Defendant for $185,718. The Supreme Court held (1) Defendant's appeal from the order denying his motion for change of venue is dismissed for lack of jurisdiction; and (2) disputed facts existed concerning Defendant's claim that he was owed an additional $12,500 under the sales agreement. View "Stromberger Farms, Inc. v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the trial court declaring that the School the City of Richmond's School Board's UM/UIM motorist coverage was $1 million, as provided in the contract between the School Board and the Virginia Association of Counties Group Self-Insurance Risk Pool (VACORP), holding that the $1 million in UM/UIM coverage the School Board contracted for was the amount of available UM/UIM coverage.Maisia Young was injured while riding a school bus. Young filed suit against the School Board seeking damages for her personal injuries. The School Board was self-insured through a self-insurance risk pool managed by VACORP. Young filed a declaratory judgment action to determine the extent of the coverage available to the School Board under the UM/UIM provisions of its contract. VACORP argued that $50,000 was the maximum amount of coverage available, as set by statute. In response, Young argued that the statutes set a minimum, not a cap, and that the maximum available was what was specified in the contract. The circuit court agreed with Young. The Supreme Court affirmed, holding that the School Board's UM/UIM coverage was $1 million, as provided in the contract between the School Board and VACORP. View "VACORP v. Young" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court awarding FoxFire Towing damages in the amount of $56,595, holding that the doctrine of quantum merit was not applicable in this case and that while FoxFire was entitled to relief under a theory of unjust enrichment it was only to the extent that T. Musgrove Construction Company was benefitted.Musgrove owned a truck that was involved in an accident. FoxFire returned the truck to an upright position, towed the damaged truck away and stored it, and cleaned up the scene. FoxFire sent Musgrove a bill for $12,380. When Musgrove did not pay, FoxFire sued. By the time the suit was filed the storage fees had risen to $28,980. The jury returned a verdict in the amount of $56,595. Musgrove appealed, arguing that most of the charges FoxFire impressed were unjustified because they constituted a recovery that was not warranted under the doctrine of unjust enrichment. The Supreme Court reversed in part, holding (1) a cause of action for quantum merit did not apply; and (2) established principles governing the unjust enrichment remedy foreclosed recovery for some of the charges FoxFire sought to obtain. View "Musgrove Construction Co. v. Young" on Justia Law