Justia Contracts Opinion Summaries

Mark Nelson, operating North Country Weatherization Technologies, provided ice removal services to Pine View First Addition Association, a Minnesota non-profit homeowners' association, in spring 2023. Pine View's property manager, a North Dakota LLC, contacted Nelson for urgent ice removal due to water damage. Nelson completed the work and invoiced Pine View, but payment was delayed, allegedly due to Pine View's attempt to have insurance cover the costs. Nelson filed a lawsuit in North Dakota for breach of contract and unjust enrichment, seeking $79,695 plus interest and attorney’s fees.The District Court of Cass County, East Central Judicial District, granted Pine View's motion to dismiss for lack of personal jurisdiction, concluding that North Dakota did not have jurisdiction over Pine View, as it is a Minnesota entity and the services were performed in Minnesota. The court also denied Pine View's motion for Rule 11 sanctions against Nelson and his attorney, as well as Nelson's request for prevailing party attorney’s fees.The Supreme Court of North Dakota reviewed the case and reversed the district court's decision. The Supreme Court held that North Dakota has specific personal jurisdiction over Pine View because Pine View, through its North Dakota-based property manager, initiated contact with Nelson for the ice removal services. The court found that Pine View's contacts with North Dakota were sufficient to satisfy the state's long-arm provision and due process requirements. The Supreme Court also determined that the district court abused its discretion in denying Nelson's request for prevailing party attorney’s fees under Rule 11(c)(2), as Pine View's motion for sanctions against Nelson violated Rule 11(c)(5)(A). The case was remanded for further proceedings and to determine the amount of attorney’s fees Nelson is owed. View "Nelson v. Pine View First Addition Association" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely under Kansas’s five-year statute of limitations for breach-of-contract claims. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, concluding that the policy's cost-of-insurance provision was ambiguous and should be construed against Kansas City Life. The jury awarded over $5 million in damages, which was reduced to $908,075 under the statute of limitations. Both parties appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the cost-of-insurance provision in the policy did not include profits and expenses, as these were not listed factors. The court also upheld the class certification, finding that common questions of law and fact predominated over individual issues. Additionally, the court agreed with the district court's application of Kansas law for the conversion claim and the statute of limitations for the breach-of-contract claim. The court found that the jury's damages award was supported by sufficient evidence and did not warrant an increase. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Digital Forensics Corporation, LLC ("DFC") was retained by King Machine, Inc. and Hartford Fire Insurance Company to perform electronic-discovery services related to a discovery order in litigation in the Etowah Circuit Court. The plaintiffs alleged that DFC misrepresented its capabilities on its website and through its representatives, leading them to believe DFC could perform the required services. Despite paying DFC $35,291.93, the plaintiffs claimed DFC failed to deliver the data in a usable format, resulting in additional costs and sanctions totaling $50,291.93, plus $107,430.44 in attorneys' fees and expenses.The plaintiffs filed a lawsuit in the Jefferson Circuit Court, alleging breach of contract and fraud in the inducement. DFC removed the case to federal court, which later remanded it back to the circuit court. DFC then filed a motion to compel arbitration based on a clause in their agreement, which included a multi-step dispute resolution process culminating in binding arbitration. The plaintiffs opposed the motion, arguing that the arbitration clause was fraudulently induced.The Jefferson Circuit Court denied DFC's motion to compel arbitration. DFC appealed to the Supreme Court of Alabama, arguing that the arbitration provision should be enforced. The Supreme Court of Alabama reviewed the case de novo and determined that the plaintiffs' fraud claims were directed at the entire agreement, not solely the arbitration clause. Therefore, the allegations of fraud in the inducement did not provide a basis to avoid arbitration.The Supreme Court of Alabama reversed the circuit court's order denying DFC's motion to compel arbitration and remanded the case for further proceedings consistent with its opinion. View "Digital Forensics Corporation, LLC v. King Machine, Inc." on Justia Law

Plaintiffs, a group of hospice service providers in Oklahoma, sued Defendant Axxess Technology Solutions, Inc. for breach of contract, alleging that Axxess failed to properly process claims, resulting in non-payment for services. Axxess was served but mistakenly believed it had not been due to an employee error. Consequently, Axxess did not respond to the complaint, leading the district court to enter a default judgment against it. Axxess moved to set aside the default judgment, arguing the court lacked subject matter jurisdiction due to a contractual mediation requirement. The district court denied this motion, and Axxess did not appeal.Over six months later, Axxess filed a second motion to set aside the default judgment, citing Federal Rule of Civil Procedure 60(b)(1), (4), and (6). The district court denied this motion on claim preclusion grounds, and Axxess timely appealed.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision but not on claim preclusion grounds. Instead, it held that the district court did not abuse its discretion by denying the second motion because the arguments raised could have been presented in the first motion. The court noted that Axxess's delay in raising these arguments was sufficient reason to deny relief under Rule 60(b). The court also granted Plaintiffs' motion to amend their complaint to properly allege diversity jurisdiction, concluding that there was complete diversity between the parties. View "Choice Hospice v. Axxess Technology Solutions" on Justia Law

Two lessors, Elizabeth Franklin and Cynthia Peironnet, owned mineral interests in a tract of land in Louisiana. In 2007, Regions Bank, managing their interests, mistakenly extended a lease for the entire tract instead of a portion. Advances in drilling technology increased the tract's value, and the lessors sued Matador Resources, the lessee, to invalidate the extension. Meanwhile, they entered into a new lease with Petrohawk Energy Corporation, contingent on the invalidation of the Matador lease. The Louisiana Supreme Court upheld the Matador lease, preventing the lessors from benefiting from the more favorable Petrohawk lease.The United States District Court for the Western District of Louisiana held a bench trial in 2021, finding Regions liable for breach of contract. On remand, the court considered extrinsic evidence to determine the lease's royalty provision, concluding it should be based on gross proceeds. The court awarded damages accordingly, including prejudgment interest on past losses and discounted future losses to present value.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that the lease conveyed a gross proceeds royalty and the admission of extrinsic evidence. However, it reversed the district court's award of royalty damages plus prejudgment interest. The appellate court instructed the district court to consider actual loss data for past years when recalculating damages and to award prejudgment interest from the date each item of past damages was incurred. The case was remanded for further proceedings consistent with these instructions. View "Franklin v. Regions Bank" on Justia Law

Shawn Montgomery was severely injured when his truck was hit by a tractor-trailer driven by Yosniel Varela-Mojena, who was employed by motor carrier Caribe Transport II, LLC. The shipment was coordinated by C.H. Robinson Worldwide, Inc., a freight broker. Montgomery sued Varela-Mojena, Caribe, and Robinson, alleging that Robinson negligently hired Varela-Mojena and Caribe and was vicariously liable for their actions.The United States District Court for the Southern District of Illinois granted partial summary judgment in favor of Robinson on the vicarious liability claim, finding that Varela-Mojena and Caribe were independent contractors, not agents of Robinson. Following the Seventh Circuit's decision in Ye v. GlobalTranz Enterprises, Inc., which held that the Federal Aviation Administration Authorization Act (FAAAA) preempts state law claims against freight brokers for negligent hiring, the district court also granted judgment for Robinson on the negligent hiring claims. Final judgment was entered in favor of Robinson to facilitate Montgomery's appeal, while his claims against Varela-Mojena and Caribe were stayed.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that Robinson did not exercise the necessary control over Caribe and Varela-Mojena to establish an agency relationship, thus negating vicarious liability. The court also declined to overrule its precedent in Ye, maintaining that the FAAAA preempts state law negligent hiring claims against freight brokers. Consequently, the court affirmed the district court's judgment in favor of Robinson. View "Montgomery v. C.H. Robinson Company" on Justia Law

Duane and Melody Remington purchased a campground and later discovered various defects on the property. They sued the seller, Keith Grimm, and the real estate agent, Bryan Iverson, alleging multiple claims including failure to disclose defects, fraudulent misrepresentation, and breach of fiduciary duty. The Remingtons claimed that Iverson and Grimm did not provide a required property disclosure statement and misrepresented the financial condition of the campground.The Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota, granted summary judgment in favor of Iverson, determining that a property disclosure statement was not required because the sale was a commercial transaction. The court did not specifically address the common law claims of nondisclosure against Iverson. The Remingtons appealed the decision.The Supreme Court of the State of South Dakota reviewed the case. The court held that a property disclosure statement was required for the living quarters of the campground, which constituted residential real property. The court affirmed the lower court's decision that a disclosure statement was not required for the non-residential aspects of the campground. The case was remanded to determine whether Iverson breached his fiduciary duty by failing to inform the Remingtons that Grimm was required to provide a property disclosure statement for the living quarters.The court also affirmed the summary judgment on the claims of Iverson’s direct liability, concluding that the Remingtons failed to establish that Iverson had actual knowledge of the alleged defects. The court dismissed Iverson’s notice of review regarding attorney fees and costs due to lack of jurisdiction. View "Remington v. Iverson" on Justia Law

Govind Vaghashia and other plaintiffs appealed a trial court order denying their motion to vacate a settlement agreement with Prashant and Mita Vaghashia. The settlement involved a $35 million payment from the Govind Parties to Prashant and Mita, with specific terms about property collateral and a quitclaim deed for a residence. Disputes arose over the interpretation of the agreement, leading to motions to enforce it by both parties. The trial court enforced the agreement but not in the manner the Govind Parties desired.The Los Angeles County Superior Court initially heard the case, where Prashant and Mita sued Govind and his affiliates, claiming a 50% interest in their business ventures. Govind counter-sued for mismanagement. A bench trial began but was paused for settlement discussions, resulting in the contested agreement. When disputes over the settlement terms emerged, both parties filed motions to enforce the agreement. The trial court ruled largely in favor of Prashant and Mita, enforcing the settlement.The California Court of Appeal, Second Appellate District, reviewed the case. The court found no abuse of discretion in the trial court's decision, holding that the Govind Parties were judicially estopped from seeking to vacate the settlement agreement after previously moving to enforce it. The appellate court noted that the Govind Parties' positions were totally inconsistent and that they had been successful in asserting the enforceability of the agreement in their initial motion. The court affirmed the trial court's orders, including the denial of the motion to vacate the settlement agreement. View "Vaghashia v. Vaghashia" on Justia Law

Condominium owners Gregory and Kathleen Haidet filed a lawsuit against their homeowners association (HOA), Del Mar Woods Homeowners Association, alleging that their upstairs neighbors' improperly installed floors constituted a nuisance. The HOA demurred to the Haidets' initial complaint, and the trial court sustained the demurrer, dismissing one cause of action without leave to amend and two with leave to amend. The Haidets chose not to amend their claims against the HOA and instead filed an amended complaint naming only other defendants. Subsequently, the Haidets filed a motion to dismiss the HOA without prejudice, while the HOA filed a motion to dismiss with prejudice. The trial court granted the HOA's request for dismissal with prejudice and awarded the HOA attorney fees.The trial court found that the Haidets' breach of contract claim failed because the governing documents did not require HOA consent for installing hardwood flooring. Additionally, the claims were time-barred as the Haidets had notice of their claims starting in 2016 but did not file until 2022. The court also found that the HOA had no fiduciary duty regarding the structural violation of the governing documents and that the business judgment rule applied to the HOA's decisions. The court dismissed the breach of fiduciary duty claim without leave to amend.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the trial court was permitted to dismiss the HOA with prejudice under Code of Civil Procedure section 581, subdivision (f)(2), as the Haidets failed to amend their claims against the HOA within the allowed time. The court also found no abuse of discretion in the trial court's determination that the HOA was the prevailing party for purposes of Civil Code section 5975 and its award of $48,229.08 in attorney fees. The judgment was affirmed. View "Haidet v. Del Mar Woods Homeowners Assn." on Justia Law