Justia Contracts Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court that Plaintiff’s implied warranty claim was actionable only under the Deceptive Trade Practices-Consumer Protection Act (DTPA), Tex. Bus. & Com. Code 17.41-17.63, holding that the claim for breach of implied warranty of good and workmanlike repairs in this case was not brought under the DTPA and thus was not covered by the DTPA’s two-year limitations period.Plaintiff sought damages for injuries to himself and his small plane when the plane’s engine failed and it crash-landed. Defendant moved to strike Plaintiff’s petition, arguing that the DTPA’s two-year statute of limitations applied. The trial court agreed with Defendant and struck the petition. The court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff’s breach of implied warranty claim was not barred by the DTPA limitations period. View "Nghiem v. Sajib" on Justia Law

The Supreme Court affirmed the trial court’s denial of Sabre Travel International, Ltd.’s motion to dismiss Deutsche Lufthansa Airline Group’s tortious interference with contract claim based on preemption, holding that the federal Airline Deregulation Act (ADA) did not preempt an airline’s claim for tortious interference with contract brought under state law.The trial court denied Sabre’s motion to dismiss but certified a legal question under Tex. Civ. Prac. & Rem. Code 51.014(d) providing for permissive interlocutory appeals. The court of appeals denied the permissive interlocutory appeal without explanation. After Sabre filed a petition for review in the Supreme Court, Lufthansa argued that the Court had no jurisdiction to hear the case because the court of appeals denied the permissive appeal. The Supreme Court held (1) under Tex. Gov. Code 22.225(d), an appellate court’s denial of a permissive interlocutory appeal does not prevent the Supreme Court from reviewing the merits of the interlocutory order; and (2) there was no preemption under the ADA. View "Sabre Travel International, Ltd. v. Deutsche Lufthansa AG" on Justia Law

The First Circuit reversed the district court’s dismissal of claims against Schechtl Maschinenbau GmbH, a German company, holding that, contrary to the conclusion of the district court, the exercise of personal jurisdiction over Schechtl comported with due process.Stephen Knox’s hand was injured at his work when he operated a machine manufactured by Schechtl. The machine had been sold to Knox’s employer by MetalForming, Inc., an American company located in Georgia and Schechtl’s U.S. distributor. Knox sued both Schechtl and MetalForming in Massachusetts state court. MetalForming removed the case to Massachusetts federal district court and filed crossclaims against Schechtl. The district court granted Schechtl’s motion to dismiss, concluding that Schechtl had not purposefully availed itself of the privilege of doing business in Massachusetts. The First Circuit reversed, holding that Knox and MetalForming met their burden of demonstrating that Schechtl purposefully availed itself of the privilege of conduct activities within Massachusetts. View "MetalForming, Inc. v. Schechtl Maschinenbau GmbH" on Justia Law

Appellants Ryan and Kathryn McFarland owned real property in Garden Valley, Idaho, which feathred three structures insured through Liberty Mutual Insurance Group: a main cabin; a detached garage with an upstairs “bonus room”; and a pump house containing a geothermal well. The policy provided two types of coverage for structures. Coverage A (“Dwelling Coverage”) provided up to $188,500 in coverage for “the dwelling on the ‘residence premises’. . . including structures attached to the dwelling . . .” and Coverage B (“Other Structures Coverage”) provided up to $22,350 for “other structures on the ‘residence premises’ set apart from the dwelling by clear space.” In February 2017, a radiant heater burst in the bonus room and damaged the garage and its contents. After the McFarlands filed a claim, Liberty stated that the damage was covered under the policy. Believing the damage to fall under the Dwelling Coverage, the McFarlands hired contractors to repair the damage. However, after Liberty paid out a total of $23,467.50 in March 2017, Liberty stated that the coverage was exhausted because the damage fell under the Other Structures Coverage. This led the McFarlands to sue, alleging among other claims, breach of contract based on Liberty’s interpretation of the policy. The parties filed cross motions for summary judgment on the issue of whether the damage fell under the Dwelling Coverage or the Other Structures Coverage. Ruling that the policy unambiguously provided coverage for the garage under the Other Structures Coverage, the district court denied the McFarlands’ motion and granted Liberty’s. The McFarlands appealed. Finding that the policy at issue here failed to define the term "dwelling", and the term was reasonably subject to differing interpretations, the Idaho Supreme Court reversed the award of summary judgment and remanded for further proceedings. View "McFarland v. Liberty Insurance Corp" on Justia Law

Until recently, Sexing Tech held a monopoly on the market for sexed cattle semen in the United States. Sperm‐sorting technology separates bull semen into X‐chromosome bearing and Y‐chromosome bearing sperm cells; the resulting “sexed semen” is used to inseminate cows artificially so that dairy farmers can breed only milk‐producing cows. ABS, a bull‐stud operation, sued, alleging that Sexing Tech had unlawfully monopolized the domestic sexed‐semen market in violation of section 2 of the Sherman Act by using its market power to impose coercive contract terms. ABS sought a declaratory judgment proclaiming those contracts invalid, to permit its own entry into that market. Sexing Tech counterclaimed that ABS infringed its patents and breached the contract by misappropriating trade secrets in developing ABS’s competing technology. Three claims went to trial: ABS’s antitrust claim and Sexing Tech’s patent infringement and breach of contract counterclaims. The Seventh Circuit affirmed the district court, holding that ABS violated a confidentiality agreement it had with Sexing Tech and that Sexing Tech’s patent was not invalid on obviousness grounds. The jury’s assessments of two of the three patent claims still at issue cannot be reconciled under the rules governing dependent claims and enablement, and so a new trial is necessary on them. View "ABS Global, Inc. v. Inguran, LLC" on Justia Law

In this appeal involving a dispute over payment for the construction of a traditional timber frame home, the Supreme Judicial Court affirmed the judgment of the superior court calculating the damages recoverable under the Unfair Trade Practice Act (UTPA) stemming from Contractor’s violation of the Home Construction Contracts Act (HCCA), holding that, the superior court did not err in its judgment.Contractor brought this action seeking to be paid for his unpaid labor. The superior court concluded (1) Contractor was entitled to the money he had already received from Homeowners under the theory of quantum meruit; (2) Homeowners did not meet their burden of proof as to their counterclaims; and (3) Contractor violated the HCCA by failing to furnish a written contract, which was prima facie evidence of a UTPA violation. The Supreme Judicial Court affirmed, holding (1) while the parties did not sign a contract in this case, the superior court’s application of quantum meruit was appropriate; (2) the superior court did not err in concluding that Homeowners failed to prove their counterclaims; (3) Homeowners were not entitled to additional damages under the UTPA; and (4) the attorneys fees award in this case was sufficient. View "Sweet v. Breivogel" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming the judgment of the district court in favor of Appellee, Appellant’s landlord, holding that Appellant’s violation of his lease in three ways that were independent from his possession of marijuana justified Appellee’s termination of the lease.Appellee issued Appellant a notice that it was terminating the parties’ lease, stating that Appellant’s use and possession of marijuana, as well as some of Appellant’s other activities, violated the terms of the parties’ lease. Appellee then filed an forcible entry and detainer complaint, and the district court entered judgment granting possession of the apartment to Appellant. Appellant appealed, arguing that because he had a certificate to use marijuana for medical purposes, Appellee and the district court were required to reasonably accommodate his possession and use of marijuana. The Supreme Judicial Court affirmed, holding that Appellant’s violations of his lease that were independent from his possession of marijuana, standing alone, justified Appellee’s termination of the lease. View "Sherwood Associates LP v. Jackson" on Justia Law

The First Circuit affirmed the decision of the district court denying SPAR Group, Inc.’s motion to compel arbitration in this case brought by Paradise Hogan against SPAR Business Services, Inc. (SBS) and SPAR, holding that SPAR could not compel Hogan to arbitrate because SPAR was not a party to the agreement containing the arbitration clause.SPAR, a retail services provider, obtained the majority of its personnel from SBS, a staffing company. After SBS engaged Hogan as an independent contractor and assigned him to perform services for SPAR, Hogan and SBS entered into an independent contractor master agreement that contained an arbitration clause. Hogan later sued SBS and SPAR, and both defendants sought to compel arbitration. The district court compelled arbitration as to Hogan’s claims against SBS but denied the motion to compel arbitration as to SPAR. SPAR appealed. The First Circuit affirmed, holding that there was no legal basis to compel Hogan to arbitration where the clear terms of the agreement showed that Hogan did not consent to arbitrate his claims against SPAR. View "Hogan v. SPAR Group, Inc." on Justia Law

Dimond was hired by a Chinese manufacturer to “rig, dismantle, wash, and pack,” and ship used automotive assembly-line equipment to China. Dimond, which lacked experience in international shipment, hired BDP. Dimond asserted that BDP did not disclose that it was not a licensed Ocean Transport Intermediary by the Federal Maritime Commission. In May 2011, BDP informed Dimond that it had obtained a ship and sent a booking note to Dimond. Between May and October 2011, Dimond dismantled and weighed the equipment and prepared a “preliminary" packing list. BDP allegedly provided the preliminary packing list when it obtained quotes from third-party contractors to load the Equipment. In October 2011, BDP notified Dimond that the ship was no longer available. Dimond asserted that BDP “without Dimond’s knowledge, consent or approval” hired Logitrans to perform BDP’s freight forwarding duties. BDP and Logitrans hired a ship. As a result of many ensuing difficulties, Dimond became involved in multiple lawsuits, including suits with its Chinese customer and the stevedores. Dimond sued BDP in July 2013 but never served BDP with the complaint. When the summons expired, the district court dismissed without prejudice. In August 2017, Dimond filed a Motion to Amend and Praecipe for Issuance of Amended Summons for its 2013 suit. The Sixth Circuit affirmed the denial of the motion. The suit was not timely filed within the one-year statute of limitations set forth in the Carriage of Goods by Sea Act. View "Dimond Rigging Co. v. BDP International, Inc." on Justia Law

At issue in this appeal were commercial general liability policy exclusions that barred coverage for damage to “that particular part” of the property on which an insured is performing operations, or which must be repaired or replaced due to the insured’s incorrect work. The Tenth Circuit concluded the phrase “that particular part” was susceptible to more than one reasonable construction: it could refer to the distinct component upon which an insured works or to all parts ultimately impacted by that work. The Court surmised the contract had to then be interpreted consistent with the mutual intent of the parties, with the ambiguity resolved most favorably to the insured and against the insurance carrier. The Court adopted the narrower interpretation of the phrase “that particular part,” under which the exclusion extends only to the distinct components upon which work was performed. This conclusion was contrary to the district court's interpretation, and therefore reversed and remanded for further proceedings. View "MTI v. Employers Insurance Co." on Justia Law