Justia Contracts Opinion Summaries

El Paso Marketing, L.P. provided gas for a power plant owned by Wolf Hollow I, L.P. The gas was transported to the plant through a pipeline owned by Enterprise Texas Pipeline LLC. El Paso sued Wolf Hollow, and Wolf Hollow counterclaimed. El Paso brought a third-party claim against Enterprise, and Wolf Hollow brought a cross-claim against Enterprise. Wolf Hollow’s claims concerned interruptions in gas delivery and allegedly contaminated gas that both required purchases of replacement power. The trial court granted summary judgment for El Paso and Enterprise. The Supreme Court remanded in Wolf Hollow II. On remand, the trial court granted summary judgment for El Paso on Wolf Hollow’s gas-quality claim and issued declarations regarding the claim. The court of appeals in Wolf Hollow III concluded that the Supreme Court had rejected the declarations in Wolf Hollow II and thus remanded the case for trial on Wolf Hollow’s claims for replacement-power damages for the failure to deliver quality gas. The Supreme Court reversed the court of appeals’ judgment relating to Wolf Hollow’s gas-quality claim for replacement-power damages, holding that the court of appeals erred in Wolf Hollow III insofar as it held that the Court’s Wolf Hollow II decision precluded it from reviewing questions regarding whether the declarations applied to that claim, and otherwise affirmed. View "El Paso Marketing, L.P. v. Wolf Hollow I, L.P." on Justia Law

Petitioner had a one-year contract to serve as the head women’s basketball coach and a professor with Trinity Valley Community College (TVCC), a local governmental entity. Five months into the contract, TVCC fired Petitioner. Petitioner sued for breach of contract. The trial court dismissed the case, concluding that TVCC was immune from suit. The court of appeals affirmed, concluding that the Local Government Contract Claims Act, which waives a local governmental entity’s immunity from suit for breach of a services contract, does not waive immunity from suit for breach of employment contracts. The court of appeals affirmed. The Supreme Court reversed, holding that the Act covers government employment contracts generally, and therefore, TVCC’s immunity from suit had been waived for Petitioner’s breach-of-contract claim. View "Damuth v. Trinity Valley Cmty. College" on Justia Law

Pawtucket Redevelopment Agency (PRA) filed a complaint against Patricia Brown alleging that the PRA had entered into an agreement with Defendant to loan her $100,000 toward the purchase and maintenance of a classic diner and that Defendant had breached the agreement by defaulting on repayment of the advance and refusing to repay the loan. Defendant filed an answer and a counterclaim. A jury returned a verdict in favor of the PRA on its book account claim and also rendered a verdict in favor of Defendant on her negligent misrepresentation counterclaim. The PRA subsequently filed a renewed motion for judgment as a matter of law and a motion for a new trial on Defendant's counterclaim. The trial justice denied the motion for judgment as a matter of law but granted the motion for a new trial, concluding that the damages awarded to Defendant was against the fair preponderance of the evidence. The Supreme Court affirmed, holding (1) Plaintiff did not timely appeal the denial of its motion for judgment as a matter of law; and (2) the trial justice did not err in granting the PRA’s motion for a new trial and to set aside the jury verdict on Defendant’s counterclaim. View "Pawtucket Redevelopment Agency v. Brown" on Justia Law

Petitioners Susan and Peter White appealed a superior court order denying their petition for a declaratory judgment that respondent Charles Matthews was covered under a homeowner's insurance policy issues to his mother by respondent Vermont Mutual Insurance Company. Matthews' dog bit Mrs. White while Matthews was staying with friends at the mother's home in Moultonborough. The policy defined an "insured" to include "residents of your household who are… your relatives." Matthews’s mother also owns a home in Naples, Florida, where she lives for approximately half of the year, and where Matthews usually visits only at Christmas. The petitioners and Matthews claim that the Florida residence is Matthews’s mother’s primary residence, but they do not claim that Matthews is a resident of the Florida home. Matthews testified that he lived in Massachusetts for 80% or more of the year. However, he had not changed his voting registration since he first registered to vote when he was eighteen, and he was still registered to vote in Moultonborough (he voted in Moultonborough in the 2012 election, a month before the hearing in this case). Matthews also held a New Hampshire driver’s license and his vehicle was registered in New Hampshire (his decision to register his car in New Hampshire was motivated by his desire to avoid buying automobile insurance, which is required in Massachusetts). Matthews typically notifies his mother in advance of using the Moultonborough house for permission to stay there. Following the 2011 incident involving Matthews' dog, petitioners sought a declaratory judgment that Vermont Mutual was responsible for any damages that might recover from Matthews. After a bench trial, the court denied the petition and the subsequent motion for reconsideration, finding that the policy did not contemplate Matthews as a resident of the Moultonborough house. Finding no reversible error, the Supreme Court affirmed the superior court's judgment. View "White v. Vermont Mutual Insurance Company" on Justia Law

Mountain Air sued Sundowner for breach of a contract to purchase real estate. Defendants alleged that the contract was illegal for failure to comply with subdivision laws and that it was extinguished by novation when the parties entered into a later option agreement. The court ruled in favor of defendants on both defenses. When defendants moved for an award of attorney fees, the trial court denied the motion, holding that because of illegality the attorney fees clause in the initial contract could have no effect and that the attorney fees clause in the option agreement did not encompass defendants’ affirmative defense. The appeals court agreed that defendants may not be awarded attorney fees under the illegal contract, but held that the trial court erred when it interpreted the attorney fees clause of the option agreement to exclude defendants’ affirmative defense of novation. Because the novation defense sought to enforce the option agreement and defendants raised it “because of an alleged dispute . . . in connection with [the integration] provision,” the subject matter of the novation defense falls within the subject matter covered by the attorney fees clause. View "Mountain Air, LLC v. Sundowner Towers, LLC" on Justia Law

Blessey filed suit against Jeffboat for breach of contract over a dispute regarding the purchase price of barges. The court did not reach the merits of the appeal because it concluded, under Becker v. Tidewater, Inc., that it did not have jurisdiction to review the district court's denial of Blessey's motion for partial summary judgment. In this case, Blessey seeks the court's review of the district court's disposition of a question of law, but its appeal does not fit the Becker exception because the district court conducted a jury trial. Further, even if the court were to assume arguendo that the court did not have jurisdiction, the court would affirm the district court's denial of partial summary judgment on the merits. The court also concluded that, by adducing some of the same extrinsic evidence at trial that it had sought to exclude in its motion in limine, Blessey waived its right to challenge the district court's admission of that evidence. Accordingly, the court affirmed the district court's denial of Blessey's motions for partial summary judgment and in limine. View "Blessey Marine Services, Inc. v. Jeffboat, L.L.C." on Justia Law

NAF filed suit against Trading for breach of contract and sought damages, alleging that Trading wrongfully repudiated the contract and that, as a consequence of the breach, NAF lost financing commitments provided by third parties and was unable to complete the acquisition of Hampton. On appeal, NAF challenged the district court's judgment in favor of Trading. The court certified the following question to the Supreme Court of the State of Delaware: Where the plaintiff has secured a contractual commitment of its contracting counterparty, the defendant, to render a benefit to a third party, and the counterparty breaches that commitment, may the promisee-plaintiff bring a direct suit against the promisor for damages suffered by the plaintiff resulting from the promisor’s breach, notwithstanding that (1) the third-party beneficiary of the contract is a corporation in which the plaintiff-promisee owns stock; and (ii) the plaintiff-promisee’s loss derives indirectly from the loss suffered by the third-party beneficiary corporation; or must the court grant the motion of the promisor-defendant to dismiss the suit on the theory that the plaintiff may enforce the contract only through a derivative action brought in the name of the third-party beneficiary corporation? View "NAF Holdings, LLC v. Li & Fung (Trading) Ltd." on Justia Law

Zaki filed suit against ANI for breach of contract and conversion, among other things, after ANI sold Zaki's aircraft parts without properly accounting for the sales proceeds, charging Zaki for inflated storage expenses, and failing to return the parts after Zaki terminated the consignment agreement. Zaki also requested an accounting. The court held that the district court abused its discretion when it refused to grant Zaki an accounting; the district court failed to recognize the fiduciary nature of the relationship between the parties alone constituted sufficient grounds for an accounting under Florida law and erroneously concluded that an action for damages afforded an adequate alternative; and, therefore, the court reversed and remanded. View "Zaki Kulaibee Establishment v. McFliker, et al." on Justia Law

In this case, Subodh Raysoni raised consumer fraud claims under the Fair Business Practices Act of 1975 against Payless Auto Deals, LLC, alleging that Payless gave false assurances that a used minivan never had been in a collision or otherwise damaged - assurances upon which he relied - when he purchased the minivan from Payless. Contending that the terms of their written contract rendered any such reliance unreasonable as a matter of law, Payless moved for judgment on the pleadings. The trial court granted that motion, and the Court of Appeals affirmed. Payless relied on several provisions of the contract disclaiming warranties, but the Supreme Court held that its reliance was misplaced because these disclaimers were not absolute and unequivocal enough to warrant judgment on the pleadings: "We cannot say as a matter of law that the contractual disclaimers of warranties - which are, at least arguably, equivocal and limited - preclude any reasonable reliance in this case on a written Carfax report furnished by Payless. We do not mean to suggest that the provisions of the contract upon which Payless relies would not have been most reasonably understood by a customer just as Payless argues. On these pleadings, we cannot say as a matter of law that Raysoni will be unable to show that his reliance on representations that the minivan was undamaged and never had been in a wreck - particularly the written Carfax report - was reasonable." Judgment on the pleadings ought not have been awarded to Payless. The case was reversed and remanded for further proceedings. View "Raysoni v. Payless Auto Deals, LLC" on Justia Law

With the threat of foreclosure looming on his home, Plaintiff sued Bank for failing to consider him for a mortgage loan modification, which a California class action settlement agreement required Bank to do before attempting to foreclose on Plaintiff’s home. The complaint alleged breach of contract, violation of Mass. Gen. Laws ch. 244, 35A and 35B, violation of Mass. Gen. Laws ch. 93A, and breach of the implied covenant of good faith and fair dealing. The district court dismissed the complaint in its entirety. The First Circuit vacated in part and remanded Plaintiff’s claims for breach of contract and breach of the implied covenant of good faith and fair dealing, holding (1) Plaintiff’s statutory causes of action fell short of stating a cognizable claim; but (2) the district court improperly converted Bank’s motion to dismiss Plaintiff’s contract-based claims into a motion for summary judgment, warranting a remand of those claims. View "Foley v. Wells Fargo Bank, N.A." on Justia Law