Justia Contracts Opinion Summaries

After Plaintiff was terminated from his employment with NCR Corporation, Plaintiff brought suit, alleging thirteen causes of action. The district court dismissed eleven of Plaintiff’s claims pursuant to Utah R. Civ. P. 12(b)(6). The district court subsequently granted summary judgment to Defendant on Plaintiff’s remaining two claims for wrongful discharge in breach of an employment contract and breach of the implied covenant of good faith and fair dealing. Specifically, the court concluded that Plaintiff had failed to present evidence of an employment contract between the parties sufficient to overcome the presumption of at-will employment under Utah law. The court of appeals reversed the district court’s grant of summary judgment, concluding that NCR’s corporate policy manual could be read to create an implied contract rebutting the presumption that Plaintiff was an at-will employee. The Supreme Court reversed, holding that the court of appeals erred in determining that the language contained in NCR’s policy manual evidenced an intent to form an implied-in-fact contract sufficient to overcome the presumption of at-will employment. View "Tomlinson v. NCR Corp." on Justia Law

Plaintiff filed a lawsuit against Quicken Loans, Inc., alleging that Quicken committed common law fraud and violated the West Virginia Consumer Credit and Protection Act in connection with a loan agreement between Plaintiff and Quicken. The circuit court found in favor of Plaintiff on all but one of her claims. The Supreme Court reversed in part, concluding that the circuit court improperly cancelled Plaintiff’s obligation to repay the loan principal, failed to support its punitive damages award with the correct analysis, and failed to offset the compensatory damages award against Plaintiff’s pretrial settlement with defendants who did not proceed to trial. After remand, the circuit court entered an opinion and order. The Supreme Court again reversed, holding that the circuit court (1) improperly created a lien on Plaintiff’s property; (2) erred in increasing the compensatory damages award to Plaintiff; (3) erred in awarding attorney fees and costs for both the first appellate proceeding and the post-appellate proceedings; (4) improperly increased the punitive damages award; and (5) erred in refusing to offset Plaintiff’s award of attorney fees and costs by a pretrial settlement between Plaintiff and the codefendants. Remanded. View "Quicken Loans, Inc. v. Brown" on Justia Law

Plaintiff, an architectural firm, signed an agreement with the Rhode Island Department of Human Services (DHS) to provide architectural and engineering services for renovations at a state-owned property. A Blanket Purchase Agreement (BPA) referencing the agreement stated that the compensation was not to exceed a certain amount. When Plaintiff requested additional compensation without success, Plaintiff filed a complaint in the superior court seeking relief. The matter was held in abeyance while a statutory arbitration procedure was underway. The arbitrator concluded that, while Plaintiff rendered additional services to DHS, the additional work was not authorized under the BPA, and therefore, Plaintiff was not entitled to additional compensation. Plaintiff then filed a petition to compel arbitration in the superior court against DHS. The trial justice denied relief, concluding that Plaintiff’s claims were barred by the doctrine of res judicata. The Supreme Court affirmed, holding that the doctrine of res judicata barred Plaintiff’s claims. View "Torrado Architects v. R.I. Dep’t of Human Servs." on Justia Law

Plaintiffs DISH Network Corporation and DISH Network LLC sought a declaratory judgment that their commercial general liability and excess liability insurers (collectively the Insurers), Arch Specialty Insurance Company, Arrowood Indemnity Company, Travelers Indemnity Company of Illinois, XL Insurance America, Inc., and National Union Fire Insurance Company of Pittsburgh, Pa., had a duty to defend and indemnify plaintiffs in an underlying patent infringement action. The district court granted summary judgment in favor of the Insurers, plaintiffs appealed, and the Tenth Circuit reversed and remanded for further proceedings. On remand, the Insurers moved again for summary judgment, but on different grounds. The district court granted the Insurers’ motions, and plaintiffs appealed. Finding no reversible error this time, the Tenth Circuit affirmed the district court's judgment. View "Dish Network v. Arch Specialty Insurance" on Justia Law

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