Justia Contracts Opinion Summaries

Appellant submitted a bid for a highway project in Sublette County, Wyoming and was the low bidder. The Board of County Commissioners of Sublette County awarded the contract to another bidder, a contractor that was from Sublette County. Appellant filed a complaint in the district court alleging that by not entering into the contract with Appellant, the Commissioners violated Wyo. Stat. Ann. 16-6-102(a). The district court found in favor of the Commissioners on all claims. On appeal, the Supreme Court held section 16-6-102(a) inapplicable and remanded the case for a determination of whether the award was appropriate. On remand, the district court held generally in favor of the Commissioners, finding that the Commissioners’ award was within their discretion and appropriate. The Supreme Court reversed, holding that the Commissioners’ utilization of an undisclosed preference for Sublette County contractors in awarding the public contract opened for competitive bid constituted an illegal exercise of discretion. Remanded for a determination of damages. View "W. Wyo. Constr. Co., Inc. v. Bd. of County Comm’rs" on Justia Law

Plaintiff-appellant Rachel Verdugo appealed an order granting a motion to stay based on a forum selection clause in her employment agreement with defendant-respondent Alliantgroup, L.P. The clause designated Harris County, Texas, as the exclusive forum for any dispute arising out of Verdugo’s employment, and also included a provision designating Texas law as governing all disputes. Verdugo contended the trial court erred because enforcing the forum selection clause and related choice-of-law clause violated California’s public policy on employee compensation. After review, the Court of Appeal agreed and reversed the trial court’s order. View "Verdugo v. Alliantgroup" on Justia Law

In 1993, Petitioner and Respondent, who were in a romantic relationship, entered into an oral agreement in which they agreed to purchase lottery tickets and to share equally in the proceeds of any winning lottery tickets. In 2007, Respondent purchased a winning lottery ticket and collected one million dollars. When Respondent refused to share half the proceeds with Petitioner, Petitioner filed suit for breach of an oral contract and unjust enrichment. The trial court entered judgment in favor of Respondent. The Court of Appeal affirmed in part and reversed in part, concluding (1) the breach of the alleged oral contract cause of action was barred by the statute of frauds; and (2) the district court erred in entering judgment for Respondent regarding the count for unjust enrichment. The Supreme Court quashed the Court of Appeal’s decision, holding that Petitioner’s oral agreement with Respondent to share equally in the proceeds of any winning lottery tickets they purchased fell outside the statute of frauds. View "Browning v. Poirier" on Justia Law

Drivers working for FedEx in Florida filed suit alleging a number of statutory and common-law claims against the company. At issue was whether FedEx properly classified the drivers as independent contractors. Applying Florida law, the court determined that several factors support the conclusion that the Florida drivers are independent contractors: the Operating Agreement itself identifies the drivers as independent contractors; FedEx pays the Florida drivers on a "settlement" basis; and the drivers can sell part or all of their service areas with notice or they can acquire service areas from other drivers. However, the court concluded that these contractual terms are not dispositive where, inter alia, other provisions of the Operating Agreement, together with FedEx's standard practices and procedures, seem to belie the creation of the status agreed to by the parties. Therefore, the court reversed the MDL court’s grant of summary judgment in favor of FedEx on the drivers’ employment status where there are genuine issues of matter fact as to whether the drivers are employees or independent contractors. The court affirmed the district court's grant of summary judgment in favor of FedEx on the individual claims of Plaintiff Mosher and Harting. View "Carlson v. FedEx Ground Package Sys., Inc." on Justia Law

Appellant sued Southern Farm Bureau Casualty Insurance Company (SFB) for breach of contract. SFB answered, alleging that Appellant’s claims were spurious and were made for an improper purpose. The circuit court granted summary judgment to SFB, concluding that Appellant had filed a frivolous claim against SFB without proper and reasonable investigation and imposed sanctions in the form of awarding attorney’s fees to SFB. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant was not entitled to an award of attorney’s fees because he did not prevail on the issue of his entitlement to the payment of a sum he sought; and (2) because SFB failed to comply with the requirements of Ark. R. Civ. P. 11 in seeking Rule 11 sanctions, the circuit court erred in imposing Rule 11 sanctions. View "Swindle v. State" on Justia Law

Plaintiff purchased a manufactured home from Defendant. The contract between Plaintiff and Defendant included an arbitration clause. Plaintiff later sued Defendant alleging fraud, negligence, breach of contract, and negligent misrepresentation. Defendant filed a motion to dismiss or to stay the court action and to compel arbitration. Plaintiff opposed arbitration, arguing that the arbitration agreement lacked mutuality and was unconscionable on multiple grounds. The trial court overruled Defendant’s motion. The Supreme Court reversed, holding (1) the agreement’s “anti-waiver clause” was unconscionable and invalid, but the anti-waiver provision could be severed; (2) Plaintiff’s remaining objections did not render the contract as a whole unconscionable; and (3) absent the anti-waiver clause, the contract was not unconscionable. View "Eaton v. CMH Homes, Inc." on Justia Law

Unison, a South Korean company, manufactures, sells, delivers, and services Wind Turbine Generators (WTGs). JEDI is incorporated and located in Minnesota. In a Turbine Supply Agreement (TSA), Unison agreed to design, manufacture, and sell two WTGs to JEDI for installation in Minnesota for $2,574,900. In a Financing Agreement (FA), Unison agreed to lend to JEDI the TSA contract price. Unison sued JEDI in federal court in Minnesota, asserting 17 claims for relief under the FA. JEDI moved to compel arbitration, based on an arbitration clause in the TSA. The district court denied the motion. The Eighth Circuit reversed, concluding that the arbitration clause in the TSA covers the dispute. The court noted multiple cross-references, and the interdependent nature of the parties’ obligations under both the TSA and the FA, and concluded that they are “two parts of one overarching business plan between the same parties.” View "Unison Co., Ltd. v. Juhl Energy Dev., Inc." on Justia Law

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