Justia Contracts Opinion Summaries

Plaintiff-Appellant Mastercraft Floor Covering, filed a lawsuit against Charlotte Flooring (CFI), a North Carolina corporation, in Oklahoma. Mastercraft alleged that CFI had hired it to install carpet in a North Carolina casino, but that after the work was completed, CFI failed to pay for the labor, services, and materials. CFI entered a special entry of appearance to object to Oklahoma having jurisdiction to decide the cause because CFI lacked the requisite minimum contacts to be sued in the State of Oklahoma. The trial judge, determined that Mastercraft failed to prove that CFI had sufficient minimum contacts to permit Oklahoma to exercise jurisdiction over CFI without offending conventional notions of fair play and substantial justice. Mastercraft appealed, and the Court of Civil Appeals affirmed. Upon review, the Supreme Court concluded that because of the totality of contacts with the Oklahoma-based corporation, the trial court had personal jurisdiction. View "Mastercraft Floor Covering, Inc. v. Charlotte Flooring, Inc." on Justia Law

C.R. Weaver formed Mikart Transport, LLC in January 2011. At that time, the articles of organization named Weaver and Michael Smith as members or managers. In March 2011, Smith submitted a credit application with Tri-County Implement, Inc. After Smith failed to pay Tri-County for work it performed on two vehicles, including a Volvo semi-truck titled in Weaver's name, Tri-County refused to release the Volvo from its possession pursuant to its asserted agisters' lien on the vehicle. Weaver subsequently filed a complaint against Tri-County. In response, Tri-County filed a counterclaim against Weaver and a third-party complaint against Mikart. The district court entered judgment against Mikart, ordering it to pay for the work it performed, and awarded Tri-County attorney fees and costs. The court also held Mikart, Smith, and Weaver jointly and severally liable for these amounts. The Supreme Court reversed the portion of the district court's imposition of personal liability on Weaver for the work performed on the two vehicles, as there was no basis to hold Weaver individually liable for the obligations of Mikart to Tri-County. Remanded. View "Tri-County Implement, Inc. v. Weaver" on Justia Law

Bank and Lumber Company had business and financial relationships with Sawmill. A few years into its operation, Sawmill began experiencing serious financial difficulties. Sawmill defaulted on approximately $1.4 million in loan obligations to Bank and owed Lumber Company approximately $900,000. Proceedings were initiated in bankruptcy court and district court. While the cases were pending, Sawmill was destroyed by fire. Bank recovered approximately $980,000 from Sawmill's insurance proceeds. In a subsequent case between Bank and Lumber Company, the jury determined that neither Bank nor Lumber Company was entitled to recover damages from the other. The Supreme Court affirmed, holding that the district court did not abuse its discretion in refusing to admit into evidence a particular letter written by the Bank president. View "H.E. Simpson Lumber Co. v. Three Rivers Bank of Mont." on Justia Law

Bristol Bay Productions, LLC brought claims against author Clive Cussler in California for fraud based on allegations that he had misrepresented his readership numbers. Bristol Bay alleged Cussler told it he had sold over 100 million books when the figure was, in fact, closer to 40 million. According to Bristol Bay, it reasonably relied on those numbers when it purchased the film rights to Cussler's books and produced an ultimately unsuccessful movie based on one of them (Sahara), with resulting damages of more than $50 million. In a special verdict, a California jury found Cussler misrepresented his readership figures and that Bristol Bay reasonably relied on those misrepresentations, but that Bristol Bay's reliance on those misrepresentations did not cause its damages. Bristol Bay also sued Cussler's literary agent and publishers for fraud in Colorado based on the same allegations asserted in the California suit. Following Bristol Bay's unsuccessful appeal of the California action, the trial court dismissed Bristol Bay's Colorado action on issue preclusion grounds for failing to state a claim. The court of appeals affirmed. Bristol Bay appealed the Colorado courts' dismissal. After review, the Colorado Supreme Court concluded Bristol Bay's Colorado action was indeed barred on issue preclusion grounds. However, the Colorado Court held the trial court erred by dismissing Bristol Bay's Colorado action without converting the defendants' motion to dismiss into a motion for summary judgment. View "Bristol Bay Prods., LLC v. Lampack" on Justia Law

Buyer purchased property located within a homeowners association. Buyer, who already owned other lots within the association, later canceled the contract with Sellers because he had not received mandatory disclosures from Sellers pursuant to the Maryland Homeowners Association Act, which requires that notice be given to "a member of the public who intends to occupy or rent the lot for residential purposes." Sellers sued Buyer for breach of contract, contending that Buyer was not a "member of the public" under the statute because Buyer, as a property owner in the association, already had access to the homeowners association policies and thus did not require disclosures making him aware of the relevant applicable rules and policies. The circuit court granted Buyer's motion to dismiss, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) Buyer was a "member of the public" for purposes of the statute; but (2) the circuit court erred in granting Buyer's motion to dismiss because Sellers presented a justiciable issue of equitable estoppel based on Buyer's affirmative refusal to receive the requirement documents and information proffered to him by Sellers. View "Lipitz v. Hurwitz" on Justia Law

After Dolly Romprey was involved in an accident, Romprey and her husband (Plaintiffs) sought to recover from their insurer (Defendant) under the uninsured/underinsured motorist provisions of their automobile insurance policy. The trial court granted summary judgment in favor of Defendant, concluding that Plaintiffs' action was time-barred under the relevant statute of limitations, and the tolling provision did not apply in this case because Plaintiffs failed to satisfy the threshold requirement that their claim involved an underinsured vehicle. The Supreme Court reversed, holding (1) a genuine issue of material fact existed concerning whether Plaintiffs had met the statutory tolling provisions of the relevant statute; and (2) therefore, the trial court erred in requiring Plaintiffs to submit evidence that they had met the requirements of the statutory tolling provision. Remanded. View "Romprey v. Safeco Ins. Co. of Am." on Justia Law

Dannix, a commercial painting contractor, filed suit against SWC alleging that SWC negligently misrepresented that a certain paint product SWC sold was appropriate for a particular painting project. The court concluded that the district court did not err in deciding that Missouri's economic loss doctrine precluded Dannix's negligent misrepresentation claim. The economic loss doctrine prohibited a commercial buyer of goods from seeking to recover in tort for economic losses that were contractual in nature. The court also concluded that the district court correctly dismissed Dannix's misrepresentation complaint where the complaint did not set forth any allegations of property damage to surfaces Dannix painted. Accordingly, the court affirmed the district court's dismissal of Dannix's complaint. View "Dannix Painting v. Sherwin-Williams Co." on Justia Law

Plaintiffs, several taxpayers who managed or owned land in the vicinity of a landfill, challenged the validity of an agreement for hosting of the landfill. The district court dismissed Plaintiffs' complaint for failure to state a claim upon which relief could be granted. The court further found that the complaint was frivolous and filed in bad faith and ordered Plaintiffs to pay the landfill parties' and counties' attorney fees and costs. The Supreme Court (1) reversed the portion of the district court's judgment imposing attorney fees because the court failed to resolve doubt over the merits of the complaint in Plaintiffs' favor; and (2) affirmed the dismissal of the complaint because the reason for dismissal was relevant only to the fee issue. View "White v. Kohout" on Justia Law

John Corrado and his company (collectively, Corrado) and Life Investors Insurance Company of America (LICA) entered into a settlement agreement following a dispute. The agreement purported to bear Corrado's signature, but Corrado challenged the signatures' validity. The U.S. district court granted summary judgment to LICA, concluding that Corrado ratified the parties' contract. The U.S. court of appeals reversed. On remand, the district court found the settlement agreement authenticated. The Iowa Supreme Court answered a certified question of law by holding that if a party receives a copy of an executed contract with that party's signature thereon, even where it is not known who applied the party's signature to the contract or whether the signature was authorized, and the party does not challenge the signature or otherwise object to the contract and accepts benefits and obligations under the contract for at least six years, then the party has ratified the contract and is therefore bound by its terms. View "Life Investors Ins. Co. of Am. v. Estate of Corrado" on Justia Law

Plaintiffs Peter and Nicole Dernier appealed the dismissal of their action for: (1) a declaratory judgment that defendant U.S. Bank National Association could not enforce the mortgage and promissory note for the debt associated with plaintiffs' purchase of their house based on irregularities and fraud in the transfer of both instruments; (2) a declaration that U.S. Bank has violated Vermont's Consumer Fraud Act (CFA) by asserting its right to enforce the mortgage and note; and (3) attorney's fees and costs under the CFA. They also appealed the trial court's failure to enter a default judgment against defendant Mortgage Electronic Registration Systems, Inc. (MERS). Plaintiffs fell behind on their mortgage, and brought suit against two parties: Mortgage Network, Inc. (MNI), which is in the chain of title for both the note and the mortgage, and MERS, which is in the chain of title for the mortgage as a "nominee" for MNI. Plaintiffs sought a declaratory judgment that the mortgage was void, asserting that: (1) MERS, as a nominee, never had any beneficial interest in the mortgage; (2) MNI had assigned its interest in both instruments to others without notifying plaintiffs; and (3) no party with the right to foreclose the mortgage had recorded its interest. MNI responded that plaintiffs had named MNI as a party in error, because MNI did "not own the right to the mortgage in question." MERS did not respond. Around this time, plaintiffs received a letter in which U.S. Bank represented that it possessed the original promissory note and mortgage and that it had the right to institute foreclosure proceedings on the property. The trial court denied plaintiffs' motion to amend and dismissed plaintiffs' case for failure to state a claim. Plaintiffs appealed. After careful consideration of the trial court record, the Supreme Court concluded the trial court erred in dismissing Counts 1 and 2 of plaintiffs' amended complaint for lack of standing, to the extent that these counts alleged irregularities in the transfer of the note and mortgage unconnected to the pooling and servicing agreement. The Court affirmed as to dismissal of Counts 3 and 4 of plaintiffs' proposed amended complaint. The case was remanded for further proceedings. View "Dernier v. Mortgage Network, Inc." on Justia Law