Justia Contracts Opinion Summaries

Defendants appealed the grant of partial summary judgment in favor of seven investors. The court concluded that it had jurisdiction to review all of the orders listed in defendants' notice of appeal; the district court did not abuse its discretion in striking a certified public accountant's affidavit where he lacked personal knowledge of the conclusions he was asserting; and the district court did not err in granting plaintiffs' motion for partial summary judgment where there had been a failure of consideration as a matter of law. In regards to the district court's holding that all defendants were liable for the return of $3.5 million, the district court did not err in finding SaiNath liable based on a failure of consideration; the district court did not err in holding K.A.P liable under a theory of unjust enrichment; but, because the district court did not have the benefit of Ogea v. Merritt when it analyzed "piercing of the veil," the court remanded for the district court to consider the application of the Louisiana court's analysis as to the facts of this case. Accordingly, the court affirmed partial summary judgment as to SaiNath and K.A.P. The court vacated and remanded as to the Karsans in their individual capacities. View "Meadaa, et al. v. K.A.P. Enterprises, L.L.C., et al." on Justia Law

Defendant agreed to furnish labor, materials, equipment, and services for a pipe-replacement project at Brown University. Defendant entered into a sub-contract with Plaintiff in which Plaintiff agreed to install the pipe. After Plaintiff completed its portion of the project, Plaintiff filed breach of contract and quantum meruit claims against Defendant, alleging that Defendant failed to pay for some of the work that Plaintiff performed on the project. The superior court entered judgment in favor of Plaintiff on its quantum meruit claim. The Supreme Court affirmed, holding that the trial justice did not misapply the law, misconceive or overlook material evidence, or make factual findings that were clearly wrong in reaching its decision. View "Process Eng'rs & Constructors, Inc. v. DiGregorio, Inc." on Justia Law

Lawrence LaBonte, the owner of New England Development RI, LLC (N.E. Development), filed a petition seeking the reorganization and/or the dissolution of N.E. Development. American Steel Coatings, LLC (American Steel) filed a motion to approve secured claim attempting to recover the funds it alleged were owed pursuant to a loan agreement between the parties. The LLC’s permanent receiver and LaBonte objected to American’s motion, asserting that the loan agreement was void because the amount of interest to be charged violated the state’s usury laws. The superior court sustained the objections and voided as usurious the loan agreement. The Supreme Court affirmed, holding that the loan agreement in this case was usurious and, therefore, void. View "LaBonte v. New England Dev. R.I., LLC" on Justia Law

After the jury returned a verdict in favor of ING on its breach of contract claims, the jury awarded ING attorney's fees under Georgia law. UPS moved under Rule 59(e) to amend the judgment to set aside the award of attorney's fees or, alternatively, for a new trial on the issue of attorney's fees. The court held that the district court erred in setting the verdict aside in light of UPS's failure to move for relief under Rule 50(a) and the existence of evidentiary support in the record for the jury's verdict. The court also concluded that a new trial was not warranted. Accordingly, the court reversed the order granting UPS's motion and remanded with instructions to reinstate the verdict and resolve ING's motion to set attorney's fees. View "ING Global v. United Parcel Service Oasis Supply Corp." on Justia Law

FFCC filed suit against Lonza, alleging breach of contract and promissory estoppel claims. The court concluded that the district court properly granted summary judgment to Lonza on the contract claim because the parties did not reach a meeting of the minds as to all terms and, therefore, there was no contract formed; the district court properly granted summary judgment on the promissory estoppel claim where nothing in the Letter of Intent or in the parties' conduct suggested that Lonza made a firm promise to purchase 1000 metric tons of Diethoxymethane in 2009; the court dismissed as moot FFCC's claim that the district court abused its discretion in denying FFCC's motion for a jury trial; dismissed FFCC's appeal as it pertains to the unsealing of the record for lack of appellate jurisdiction; and affirmed the district court's grant of attorney's fees. View "FutureFuel Chemical Co. v. Lonza" on Justia Law

Charles Blackmon and Dexter Booth sued Malaco, Inc.; N.J. Pockets, Inc.; and Callop Hampton (owner of Hamp’s Place Night Club) on a premises-liability claim. Plaintiffs settled with Malaco. At trial, the jury returned a verdict in favor of Hampton. Hampton filed a post-trial motion, requesting the trial court to impose sanctions against Blackmon, Booth, and their attorney for filing a frivolous lawsuit and to award attorney fees. The motion was denied, and Hampton appealed that judgment to the Supreme Court. Finding no abuse of discretion, the Supreme Court affirmed. View "Hampton v. Blackmon" on Justia Law

This appeal involved Empire Fire and Marine Insurance Company's obligations under an "Insurance for Non-Trucking Use" policy issued to Drielick Trucking. The policy contained a business-use exclusion, which included two clauses that Empire argued precluded coverage in this case. The Court of Appeals agreed that the first clause precluded coverage when the covered vehicle was not carrying property at the time of the accident, was in this case. Thus, the Court of Appeals expressly declined to address the second clause relating to leased covered vehicles. The Supreme Court held that the Court of Appeals erred in its interpretation of the first clause. The case to the trial court for further fact-finding to determine whether Drielick Trucking and Great Lakes Carriers Corporation (GLC) entered into a leasing agreement for the use of Drielick Trucking’s semi-tractors as was contemplated under the policy's clause related to a leased covered vehicle. View "Estate of Eugene Hunt v. Drielick" on Justia Law

In January 2006, two former payday lenders, defendants B&B Investment Group, Inc., and American Cash Loans, LLC, began to market and originate high-cost signature of $50 to $300, primarily to less-educated and financially unsophisticated individuals. The loans were for twelve months, payable biweekly, and carried annual percentage rates ranging from 1,147.14 to 1,500%. The Attorney General’s Office sued Defendants, alleging that the loan products were procedurally and substantively unconscionable under the common law and that they violated the Unfair Practices Act (UPA). The district court found that Defendants’ marketing and loan origination procedures were unconscionable and enjoined certain of its practices in the future, but declined to find the high-cost loans substantively unconscionable, concluding that it is the Legislature’s responsibility to determine limits on interest rates. Both parties appealed. Upon review, the Supreme Court affirmed the district court’s finding of procedural unconscionability. However, the Court reversed the district court’s refusal to find that the loans were substantively unconscionable because under the UPA, courts have the responsibility to determine whether a contract results in a gross disparity between the value received by a person and the price paid. The Supreme Court concluded that the interest rates in this case were substantively unconscionable and violated the UPA. View "New Mexico ex rel. King v. B&B Investment Group, Inc." on Justia Law

Appellants filed a class action complaint alleging that the circuit court clerk falsely and fraudulently notarized oil-and-gas leases outside the presence of the landowners. The complaint requested an injunction and other relief. After a hearing, the circuit court sua sponte dismissed the case for lack of damages. The Supreme Court reversed, holding that the circuit court improperly dismissed Appellants’ complaint, as the sua sponte dismissal foreclosed the possibility that Appellants might have been able to submit additional evidence indicating that there remained a genuine issue of material fact, i.e., that they had suffered damages. View "Lipsey v. Giles" on Justia Law

The Club is a non-profit provider of protection and indemnity insurance. The Club's Rules include a choice-of-law provision selecting New York law and a two-year statute of limitations for claims against the Club. The Club filed a civil action against defendant alleging that it breached the insurance contract by failing to reimburse the Club for a shortfall and by failing to pay the overdue insurance premiums. The court agreed with the district court, and precedent, that an otherwise valid choice-of-law provision in a maritime contract is enforceable and may require application of a jurisdiction's statute of limitations, in lieu of the doctrine of laches, to govern issues regarding the timeliness of claims asserted under that agreement. Accordingly, the court held that the district court correctly applied New York's six-year statute of limitations to the Club's claims arising under its maritime insurance contract with plaintiff. Therefore, the court affirmed the judgment of the district court. View "American Steamship Owners v. Dann Ocean Towing, Inc." on Justia Law