Justia Contracts Opinion Summaries

Lender loaned Borrowers $52,000 pursuant to a loan agreement (agreement) and promissory note ( note). After Borrowers stopped making payments on the loan, Lender filed a petition to collect the total principal due on the agreement and note. The trial judge determined (1) Lender did not meet its burden to prove a breach of contract on the agreement and note because it did not show evidence of the terms of the agreement and repayment schedule, and (2) even if there was an enforceable contract, Lender failed to prove damages. The Supreme Court reversed, holding (1) the record established as a matter of law that Lender proved the existence of a contract based upon the agreement and note; and (2) the district court applied the wrong burden of proof to determine a breach and the amount of damages owed, if any, on the agreement and note. Remanded. View "Iowa Mortgage Ctr., LLC v. Baccam" on Justia Law

Eugene and Charlene Guthmiller appealed a district court judgment finding an option agreement should have been honored, allowing Guthmiller Farms, LLP and Jeremy Guthmiller to each purchase by contract for deed an undivided one-half interest in specified lands. The Guthmillers argued on appeal: (1) that Guthmiller Farms did not have standing to pursue the action; (2) that consideration was invalid for the option contract; (3) that exercise of the option constituted a counteroffer; and (4) that the district court erred in considering evidence not disclosed prior to the hearing. Finding no error, the Supreme Court affirmed. View "Guthmiller Farms v. Guthmiller" on Justia Law

Charles Gower petitioned the Supreme Court to vacate an arbitration award in favor of Turquoise Properties Gulf, Inc., Caribe Realty, Inc., Larry Wireman, and Judy Ramsey Wireman(collectively, "Turquoise"). The underlying dispute arose from Gower's preconstruction agreement to purchase a condominium unit in a complex developed by Turquoise. The arbitrator's decision was based in large part on Turqoise's successfully raising a statute-of-limitations defense to Gower's claims. The Supreme Court found that Turquoise expressly argued, and then abandoned, one specific statute-of-limitations defense and then it never again urged the arbitrator to apply a statute of limitations to the various claims actually brought by the claimants. Through its arguments, Turquoise distilled the issues and arguments submitted to the arbitrator for consideration. Gower argued, and the Supreme Court agreed, that Turquoise "affirmatively chose to forgo any statute of limitations defense to the [c]laimants' ... claims and therefore did not submit [the] same to the Arbitrator for decision." Therefore, the Supreme Court concluded that because the issue of the applicability of a statute of limitations was not submitted to the arbitrator for decision, the arbitrator exceeded his powers in applying a statute of limitations to Gower's claims. The Court reversed the judgment entered on the arbitrator's award, and remanded the case for further proceedings. View "Gower v. Turquoise Properties Gulf, Inc., et al. " on Justia Law

Immunosciences developed and sold medical tests and testing materials. In 2007, NeuroSciences wanted to expand its offerings. Immunosciences and NeuroScience decided to collaborate, but the relationship fell apart within two years. Immunosciences sued. In the first trial, a jury rejected a claim that NeuroScience did not pay what it had contracted to pay for medical testing materials, but the district judge ordered a new trial, concluding that the verdict was undermined by flawed special verdict questions. The jury in the second trial found for Immunosciences but awarded much less money than it was seeking. NeuroScience appealed, claiming that the court’s grant of a new trial was an abuse of discretion. Immunosciences argued that the court abused its discretion by allowing NeuroScience to argue in the new trial that the parties had orally modified their written contract and that NeuroScience breached a separate confidentiality agreement by continuing to use Immunosciences’ testing methods after the parties ended their business relationship. The jury in the first trial had awarded nearly $1.2 million on that claim, but the district court granted judgment as a matter of law for NeuroScience, explaining that Immunosciences had relied on an impermissible damages theory. The Seventh Circuit affirmed. View "Vojdani v. Pharmasan Labs, Inc." on Justia Law

Horsfall worked as a real estate agent for First Weber, 2001-2002, and was the listing agent on First Weber’s contract with Call, who was trying to sell property. The contract gave First Weber exclusive rights collect commissions for sale of the property during the listing period and an exclusive right to collect commissions from sales to defined “protected buyers” for one year after the listing expired. The Acostas made an offer on the property and became “protected buyers.” Call’s contract with First Weber ended in August and at the same time, Horsfall left First Weber to establish his own brokerage, Picket Fence. In October, the Acostas contacted Horsfall. Without involving First Weber, Horsfall resuscitated the transaction with Call. The Acostas and Call executed a sales contract for the Call property. Picket Fence received a $6,000 commission, inconsistent with Horsfall’s status as First Weber’s agent under the earlier contract and in violation of Wisconsin real estate practice rules. Six years later, First Weber sued Horsfall in state court, asserting r breach of contract, tortious interference, and unjust enrichment. The state court entered a judgment against Horsfall for $10,978.91. Horsfall filed for Chapter 7 bankruptcy, listing First Weber as a creditor. First Weber responded that its judgment was non‐dischargeable under 11 U.S.C. 523(a)(6), as involving “willful and malicious injury.” The bankruptcy court, district court, and Seventh Circuit found the debt dischargeable. View "First Weber Grp., Inc. v. Horsfall" on Justia Law

Plaintiff-appellant Anil Vazirani was an independent insurance agent who owned and managed Vazirani & Associates Financial, LLC and Secured Financial Solutions, LLC. Vazirani contracted with Aviva Life and Annuity Company. After Defendants Mark Heitz and Jordan Canfield, executives at Aviva, cancelled the contract, Vazirani sued them in federal district court, alleging that they tortuously interfered with the contract. The district court awarded summary judgment to Defendants, holding that an officer of a company could be liable for tortious interference with a company contract only if he was motivated by solely personal interests. The court concluded Vazirani failed to produce evidence that defendants were motivated by solely personal interests in terminating the contract. Finding no error with that decision, the Tenth Circuit affirmed. View "Vazirani v. Heitz" on Justia Law

American West Enterprises appealed a district court's grant of summary judgement to Case New Holland, Inc. (CNH) in its effort to recover the cost of a remanufactured tractor engine CNH sold to a local seller that American West purchased. The district court dismissed American West's claim of implied warranty because there was no privity between American West and CNH. The district court also rejected American West's claims that it was an intended third party beneficiary of a contract between CNH and Pioneer and that Pioneer was an agent of CNH. American West appeals. The district court denied CNH's request for attorney fees and costs below. CNH cross-appealed. Finding no error, the Supreme Court affirmed all but the denial of attorney fees. The case was remanded to the district court for finding costs and fees in favor of CNH. View "American West Ent. v. CNH, LLC." on Justia Law

The issue before the Supreme Court in this case centered on a contract dispute between the State of Vermont and Corizon Health, Inc., formerly known as Prison Health Services, Inc. (PHS). The State appealed a declaratory judgment ruling that PHS was not contractually obligated to defend the State and its employees against certain claims brought by the estate of an inmate who died while in the custody of the Department of Corrections.  Upon review of the contract in question, the Supreme Court reversed, concluding that PHS had a duty to defend. View "Vermont v. Prison Health Services, Inc." on Justia Law

Defendant appealed the trial court's refusal to vacate a default judgment against it. This dispute arose from a 2009 contract between plaintiff LaFrance Architect, d/b/a Lake Architectural, and defendant Five Point Development South Burlington, LLC. Under the contract, plaintiff was to provide defendant architectural services for the construction of a Walgreens in South Burlington. Plaintiff invoiced defendant for services rendered, but two days after the invoice was payable and three days after the store opened, defendant sent plaintiff a letter indicating that defendant was terminating plaintiff's services due to an unspecified failure to fulfill the contract and unspecified "significant design errors that caused additional costs."  Plaintiff responded by filing notice of a mechanics lien. Defendant then secured a bond to discharge the mechanics lien, but failed to send a copy of the bond to plaintiff. Plaintiff later filed suit to perfect its mechanics lien by filing a verified complaint with a request for attachment and a claim for damages. Because the parties' contract contained mandatory mediation and arbitration provisions, plaintiff also filed a motion for stay, requesting that the court consider its motion for attachment but then stay proceedings pending mediation and arbitration as required by the contract. Upon review of the matter, the Supreme Court held that the trial court improperly declined to consider the strength of defendant's proffered defenses to its motion to vacate the default judgment, but that defendant's Rule 60(b) motion did not establish a prima facie case to support a meritorious defense. Therefore the Court affirmed the trial court's decision. View "LaFrance Architect v. Five Point Development South Burlington, LLC" on Justia Law

Plaintiff was the minor beneficiary of a $100,000 life insurance policy. Plaintiff filed a complaint against his financial guardian and the insurance company after the guardian misappropriated the insurance proceeds. The trial court entered judgments in favor of Plaintiff. The insurance company appealed. The court of appeals affirmed, concluding that, by entrusting the proceeds to the guardian, the insurance company breached its contractual duties. The Supreme Court reversed, holding (1) the insurance company acted in good faith when it relied upon the validity of a juvenile court order establishing a financial guardianship in making payment of the life insurance proceeds, and (2) therefore, the insurance company could not be liable for breach of contract. View "Hood v. Jenkins" on Justia Law