Justia Contracts Opinion Summaries

Allstate Insurance Company petitioned for review of a court of appeals' judgment that reversed the dismissal of a breach of assignment claim brought by Medical Lien Management (MLM). The district court effectively construed MLM's Lien and Security Agreement with a motor vehicle accident victim (upon which the underlying complaint was premised), as failing to assign the victim's right to the proceeds of his personal injury lawsuit against Allstate's insured. The court of appeals found a valid assignment to MLM all rights to the future proceeds from the personal injury claim in an amount equal to the costs of medical services paid for by MLM, as well as a sufficient allegation in the complaint of an enforceable obligation by Allstate to pay the assigned sums to MLM. The Supreme Court reversed, finding that the court of appeals erred in finding the purported assignment in this case. View "Allstate Insurance Co. v. Medical Lien Management, Inc." on Justia Law

Buyer agreed to purchase a portion of a 2,700 acre ranch from Sellers. Sellers agreed to finance a portion of the purchase price by accepting Buyer’s promissory note. After Buyer defaulted on the promissory note, Sellers initiated foreclosure proceedings. Buyer and its successor in interest (collectively, Buyers) filed a complaint for declaratory judgment and a motion for a temporary restraining order to halt the foreclosure, asserting several causes of action. Sellers counterclaimed, asserting that Buyers breached the terms of the promissory note. The district court granted summary judgment in favor of Sellers. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting summary judgment in favor of Sellers with respect to Buyers’ adverse possession claim and with respect to Sellers’ breach of contract claim; and (2) erred in denying Sellers’ request for attorney’s fees. Remanded. View "Flynn v. Ruby River Canyon Ranch, Ltd." on Justia Law

The underlying lawsuit in this case, "Retailers’ Credit Association of Grass Valley, Inc. v. Leonard," was filed by real party in interest Retailers’ Credit Association of Grass Valley, Inc., and alleged petitioner Kathleen Leonard breached a contract by failing to pay $2,340.41 for medical services provided by additional real party in interest, Dignity Health, which was doing business as Sierra Nevada Memorial Hospital. Retailers’ Credit Association was the local collection agency providing collection services for Sierra Nevada Memorial Hospital. Leonard filed a pro. per. cross-complaint against Retailers’ Credit Association, alleging a violation of the Health Insurance Portability and Accountability Act of 1996 by negligent disclosure of private medical information (i.e. “date of medical visits, medical record number, [and] account numbers”). On the front page of her cross-complaint, Leonard checked the box on the form that stated, “ACTION IS A LIMITED CIVIL CASE ($25,000 or less).” In the complaint itself, Leonard checked the box requesting “compensatory damages” for “limited civil cases.” She also requested injunctive relief in the form of a court order requiring Retailers’ Credit Association to remove the allegedly private information from its complaint. Leonard later filed a pro. per. motion to amend her cross-complaint. In the caption of the motion, she stated the amendment was to “NAME SIERRA NEVADA MEMORIAL HOSPITAL AS A CROSS-DEFENDANT and TO REMOVE THIS CASE TO A COURT OF GENERAL JURISDICTION.” The memorandum of points and authorities alleged that the documents attached to the complaint contained her medical record number and were not necessary for the prosecution of the collection claim and at the very least could have been redacted to protect her privacy. When she reviewed the complaint, she “noticed the attachment to the complaint contained [her] medical records and medical record number” and that the complaint with the attachment had been filed publically at the courthouse. The trial court denied Leonard’s motion to amend the cross-complaint and “[t]ransfer to [u]nlimited [j]urisdiction” without prejudice. Leonard “failed to attach the proposed [a]mended [c]ross-[c]omplaint to the motion” and as a result, the court was “unable to determine what the proposed changes include.” The court was “unable to determine if an additional [c]ross-[d]efendant [wa]s sought to be named or if damages sought exceed $25,000. Thus, th[e] Court [w]as unable to determine if [Leonard] [wa]s entitled to the relief sought.” This case involves how a limited civil case (here a cross-complaint) gets reclassified as an unlimited civil case. After review, the Court of Appeal held that where Leonard filed, through counsel, an amended cross-complaint that added a cross-defendant and added causes of action that increased the amount in controversy to over $25,000 and tried twice to pay the court clerk the reclassification fee, the trial court was required to reclassify the case. Here, the trial court refused to reclassify the case and went on to deny Leonard’s later-filed motion for reclassification, a motion that was unnecessary because the trial court should have already reclassified the case (and in any event, the motion was the inappropriate vehicle by which to change the classification here). The Court therefore granted Leonard’s petition and issued a peremptory writ of mandate directing the trial court to reclassify the case upon Leonard paying the reclassification fee. View "Leonard v. Super. Ct." on Justia Law

James and Barbara Hilliard (Vendors) owned a farm in Owyhee County with approximately 3,000 acres of farmable land. They executed written leases of the best farm ground to various farmers who grew row crops. They orally leased to John Clark other portions of the farm, on which he raised hay and grain crops. In 2009 and 2010, Vendors leased the row crop portion of the farm to Lance Funk Farms, LLC. Because of his health, on John Clark became unable to continue farming, and Vendors orally leased to his son Jay P. Clark, Vendors’ attorney, those parts of the farm not leased for growing row crops. According to Vendors, in January 2010 Jay Clark fraudulently obtained a written document purporting to give him a one-year lease of the entire farm with an option to extend the lease for a period of ten years. He then recorded the document in the records of the county recorder, and in June 2010 his father recorded a document claiming to have a 10% interest in the farm. These recordings created clouds on the Vendors’ title to the farm. In November 2010, Vendors contracted to sell their farm to Murphy Land Company, LLC (Purchaser). Jay Clark told Purchaser that he would only vacate the farm upon payment to him of $2,000,000 and payment to his father of $950,000. Because of the two clouds on the title and the refusal of Jay Clark to vacate the property, the parties entered into an amendment to their contract which stated, among other things, that $3,000,000 of the sale price would be held in trust to “be available to the extent determined by a court of competent jurisdiction of the purchaser’s damage, if any, for loss or delay of possession of real estate purchased herein.” The sale closed on December 30, 2010. In early 2011, Vendors sued Jay and John Clark, and obtained a judgment declaring Jay Clark’s purported lease null and void and ordering that John Clark’s recorded claim to ownership of a 10% interest in the farm be expunged from the county records. Then Purchaser filed a lawsuit to have Jay Clark removed from the farm. Clark fought that lawsuit, including filing for bankruptcy protection after Purchaser was granted summary judgment in its action to remove him from the farm. As a result, Purchaser did not obtain possession of the farm until May 2012. In 2013, Vendors filed this action for a declaratory judgment that they were entitled to a $3,000,000 being held in trust. Purchaser filed a counterclaim seeking that sum for the damages it incurred due to the delay in being able to obtain possession of the farm. The district court granted summary judgment to the purchaser after holding that the material portions of the affidavits filed by the vendors in opposition to summary judgment were inadmissible. Finding no error with that judgment, the Supreme Court affirmed the district court and awarded attorney fees on appeal. View "Hilliard v. Murphy Land Co." on Justia Law

Plaintiff appealed the trial court's sustaining of a demurrer without leave to amend, ruling that plaintiff obligated himself to pay a medical bill when he signed the "Cedars-Sinai Medical Center Conditions of Admissions" (COA). The court concluded that the demurrer was properly sustained as to the Unfair Competition Law, Bus. & Prof. Code 17200 et seq.; plaintiff has forfeited his other claims and has not shown he can amend where he does not explain how he could amend his complaint to avoid demurrer, and he did not propose any proper amendments in opposition to the demurrer; and therefore, the court affirmed the judgment of the trial court. View "Nolte v. Cedars Sinai Medical Center" on Justia Law

Jarrett Smith was injured when his vehicle collided with a truck owned by Modular Building Consultants of West Virginia, Inc. and operated by Billy Joe McLaughlin. Prior to the collision, McLaughlin had arrived at a job site to retrieve a Modular storage container being leased and utilized by Poerio, Inc. Smith filed suit against Modular, alleging negligence. Modular brought a third-party complaint against Poerio, seeking contribution and indemnification pursuant to the lease agreement. Before trial, Modular settled with Smith. Trial as to Modular’s third-party complaint proceeded. A jury found that Poerio did not breach the lease agreement but found that Poerio, Modular, and Smith were all comparatively negligent. The circuit court subsequently entered judgment in Poerio’s favor on its contribution claim. The Supreme Court affirmed, holding (1) the jury’s finding that Poerio was negligent was not inconsistent with its finding that Poerio did not breach the lease agreement; (2) the circuit court erred in ruling that Modular’s contribution claim was extinguished by its good faith settlement with Smith as a matter of law; but (3) the jury’s verdict was neither inconsistent nor impermissibly considered the comparative fault of Smith. View "Modular Building Consultants of W. Va., Inc. v. Poerio, Inc." on Justia Law

Husband and wife (who did not speak English) entered into a written one-year lease, took possession of the apartment, and tendered the security deposit and first month’s rent. Ten days into the lease, they received “an official 30 days notice” of eviction, stating that “[c]onstruction begins June 10,” and that they did not qualify for an unspecified “new program.” Several additional efforts to force the family to move followed; their tender of rent was refused. They purportedly sought legal advice and were told that the landlord could not unilaterally terminate the lease. They reported feeling discriminated against and harassed; they were confused, depressed, and anxious. Demolition began while the family was occupying the apartment. Husband allegedly told wife that he could not tolerate the situation any longer. The following day, he committed suicide in the apartment. Wife sought damages for intentional infliction of emotional distress, wrongful eviction, breach of contract; under the Wrongful Death Act; and under the survival statute. The trial court dismissed the wrongful death and related survival actions, finding that “wrongful death via suicide” is not cognizable in Illinois. The Illinois Supreme Court agreed. Despite an ostensible connection between severe emotional distress and suicide, suicide may result from a complex combination of factors. It is “rare” that suicide would not break the chain of causation and bar a wrongful death action, even where the plaintiff alleges the defendant inflicted severe emotional distress. Husband’s suicide was not a reasonably foreseeable result of defendant’s alleged conduct in breaking the lease and pressuring the family to vacate. View "Turcios v. DeBruler Co." on Justia Law

This case arose from a dispute over a construction contract entered into between Contractors Edge, Inc. and the City of Mankato. Contractors Edge sued the City alleging, as relevant to this appeal, breach of contract and violation of the Prompt Payment Act. The district court dismissed the breach of contract claim in an order (the October 2012 order) that concluded, “let judgment be entered accordingly.” Neither party asked for a certification of final judgment under Minn. R. Civ. P. 54.02. The parties subsequently settled the remaining Prompt Payment Act claim. The district court entered final judgment in January 2014. Contractors Edge appealed, challenging the October 2012 order. The court of appeals dismissed the appeal as time barred, holding (1) regardless of whether the district court properly certified the October 2012 order, the partial judgment was immediately appealable, and (2) Contractors Edge’s appeal time had expired. The Supreme Court reversed, holding (1) the district court abused its discretion in certifying the October 2012 order as a final partial judgment under Rule 54.02; and (2) when a district court abuses the discretion given in Rule 54.02 to certify an order as a final partial judgment, the resulting judgment is not final and is not immediately appealable. View "Contractors Edge, Inc. v. City of Mankato" on Justia Law

Pacific appealed the Board's suspension of its license as the sanction for failing to notify the Board that a judgment had been entered against Pacific. Jerry McDaniel and his wife Delma own two corporations, Pacific and Gold Coast Drilling, Inc. The trial court found that Pacific did not substantially comply with the requirement that the contractor be licensed while performing work. Pacific argued that the judgment was not “substantially related” to its “construction activities” within the meaning of Bus. & Prof. Code 7071.17, and so Pacific’s license should not have been suspended. The court concluded that Gold Coast was obligated to notify the Board of the unsatisfied stipulated judgment where the stipulated judgment falls within the ambit of section 7071.17 and the stipulated judgment was unsatisfied; the evidence supports the trial court’s finding that Gold Coast did not “act[] reasonably and in good faith” to maintain its license; and, therefore, the court affirmed the judgment of the trial court. View "Pacific Caisson & Shoring v. Bernards Bros." on Justia Law

Beck filed suit against its franchisor, GM, for claims arising under the Motor Vehicle Dealer Act, N.Y. Vehicle & Traffic Law 460-473, and state contract law. The court certified the following questions to the New York Court of Appeals: (1) Is a performance standard that requires ʺaverageʺ performance based on statewide sales data in order for an automobile dealer to retain its dealership ʺunreasonable, arbitrary, or unfairʺ under New York Vehicle & Traffic Law section 463(2)(gg) because it does not account for local variations beyond adjusting for the local popularity of general vehicle types? and (2) Does a change to a franchiseeʹs Area of Primary Responsibility or AGSSA constitute a prohibited ʺmodificationʺ to the franchise under section 463(2)(ff), even though the standard terms of the Dealer Agreement reserve the franchisorʹs right to alter the Area of Primary Responsibility or AGSSA in its sole discretion?  Further, the court concluded that the district court did not err in dismissing plaintiffʹs vehicle allocation claim, denying plaintiffʹs request for attorneyʹs fees, or dismissing defendantʹs counterclaim for rescission. View "Beck Chevrolet v. General Motors" on Justia Law