Justia Contracts Opinion Summaries

Shane Traylor Cabinetmaker, L.L.C. ("STC"), and Michael Shane Traylor sued American Resources Insurance Company, Inc., alleging breach of contract and bad faith, based on American Resources' refusal to defend or to indemnify STC and Traylor on counterclaims filed against them by Robert Barbee and R.L. Barbee Builders, Inc. in a separate action. The circuit court entered a summary judgment in favor of American Resources, and STC and Traylor appealed. Finding no error, the Supreme Court affirmed. View "Shane Traylor Cabinetmaker, L.L.C. v. American Resources Insurance Company, Inc. " on Justia Law

This case arose from efforts of Verizon New England to collect a judgment awarded in 2009 by the U.S. district court against Global NAPs (GNAPs). Verizon served a restraining notice on GNAPs and companies with which it did business, one of which was Transcom Enhanced Services. Verizon subsequently commenced this special proceeding seeking a turnover of property and debts of the judgment debtor held by Transcom. Supreme Court denied turnover and dismissed the petition with prejudice, concluding that Transcom did not owe any debt to GNAPs and it did not hold property in which GNAPs had any interest. At issue on appeal was whether the at-will, prepayment service agreement between the parties, which lacked any obligation to continue services or a commitment to engage in future dealings, constituted a property interest or debt subject to a N.Y. C.P.L.R. 5222(b) restraining notice. The Appellate Division affirmed. The Court of Appeals affirmed, holding that, based on the nature of the agreement, the restraining notice was unenforceable. View "Verizon New England, Inc. v Transcom Enhanced Servs., Inc." on Justia Law

In 2006, Plaintiffs sustained serious injuries in an automobile accident and incurred medical expenses in excess of $1,000,000. Plaintiffs subsequently learned that they had only $5,000 in medical payments coverage and did not have any underinsured motorist (UIM) coverage after a transfer of their Oregon State Farm policy to Montana by the Mark Olson State Farm Agency. The driver who caused the accident carried the statutory minimum automobile liability insurance limits. Plaintiffs sued State Farm and Mark Olson, requesting declaratory relief and a reformation of the contract and alleging negligence, breach of fiduciary duty, and conduct sufficient to support an award of punitive damages. The district court entered summary judgment in favor of Defendants. The Supreme Court reversed, holding that the district court erred in entered summary judgment in favor of State Farm and Olson on Plaintiffs' negligence claims. Remanded for trial. View "Bailey v. State Farm Auto. Ins. Co." on Justia Law

The issue before the Supreme Court in this case concerned the proper procedure by which a workers' compensation insurer may enforce a subrogation claim arising under Mississippi Code Section 71-3-71. Richard Shoemake was injured in Alabama but received workers' compensation benefits from Liberty Mutual Insurance Company under Mississippi law. He brought and settled a third-party action in Alabama state court and reimbursed Liberty Mutual only the amount it was entitled to under Alabama law. Liberty Mutual, which knew of but did not join or intervene in the Alabama lawsuit, then sued Shoemake in the Circuit Court of Newton County, seeking full reimbursement as allowed under Section 71-3-71. In granting Shoemake summary judgment, the circuit court held that Alabama law applied and further concluded that res judicata and Liberty Mutual's failure to intervene in the Alabama action barred Liberty Mutual's claim. The Court of Appeals reversed, holding that Mississippi law governed the amount of Liberty Mutual's subrogation claim and that Liberty Mutual was not required to intervene in the Alabama action to become entitled to reimbursement under Mississippi law. Because the Mississippi Supreme Court found that 71-3-71 requires a workers' compensation insurer to join or intervene in a third-party action to become entitled to reimbursement, it reversed the Court of Appeals and affirmed the circuit court. View "Liberty Mutual Insurance Company v. Shoemake" on Justia Law

This case involved the interpretation of two contractual provisions under Minnesota law: an indemnification clause in a contract between PDSI and Miller and an insurance contract between Harleysville and PDSI which extended insurance coverage to PDSI's indemnification of third parties for tort liability caused, in whole or in part, by PDSI or by those acting on its behalf. The court agreed with the district court's finding that a PDSI employee's suit fell squarely within the indemnity provision of the 1989 Agreement between PDSI and Miller. The court also agreed with the district court's interpretation of the insurance agreements as requiring Harleysville to cover Miller's settlement of the employee's claims. Further, the court concluded that the undisputed facts established as a matter of law that PDSI or those acting on its behalf at least partly caused the employee's bodily injury within the terms of the Harleysville policy. Accordingly, the court affirmed the judgment. View "Harleysville Ins. Co. v. Physical Distrib. Serv., et al" on Justia Law

This case arose out of the payment of benefits pursuant to an Aflac accident insurance policy. Defendant and the decedent's siblings challenged the district court's entry of summary judgment and order compelling arbitration of defendant's claims against Aflac and its agents. At issue was whether defendant's affidavit, which included her opinion that the signature on the arbitration acknowledgment form was a forgery, was sufficient to create a genuine issue of material fact. The court concluded that defendant's affidavit was never made part of the summary judgment record before the district court and therefore failed to create a genuine issue of material fact on the authenticity of the decedent's signature. Accordingly, the court affirmed the district court's judgment. View "American Family Life Assurance Co. of Columbus v. Biles, et al" on Justia Law

The plaintiffs sued for damages arising out of their sales of stock in Wayport, Inc. After the defendants' motion to dismiss in part was granted, the litigation proceeded to trial against the remaining defendants on claims for breach of fiduciary duty, aiding and abetting a breach of fiduciary duty, common law fraud, and equitable fraud. The court of chancery (1) entered judgment in favor of plaintiff Brett Stewart and against defendant Trellis Partners Opportunity Fund in the amount of $470,000; and (2) otherwise entered judgment against the plaintiffs and in favor of the defendants. View "In re Wayport, Inc." on Justia Law

Landlord and Tenant entered into a twelve-year lease for commercial space. The lease required a separate guaranty agreement to be executed by Guarantor. Tenant stopped making rent payments a couple of years later, and thereafter, Landlord reentered and took possession of the premises, thereby terminating the lease. Landlord subsequently filed suit against Tenant and Guarantor for damages arising from the breach of contract. The superior court granted summary judgment to Landlord as to liability and awarded damages in the amount of $1,092,653, for which Tenant and Guarantor were jointly liable. The appeals court affirmed in part and vacated the judgment assessing damages and remanded. The Supreme Court (1) affirmed the part of the judgment finding Tenant liable for breach of the lease and assessing damages for the period before termination of the lease in the amount of $37,276 plus prejudgment interest; and (2) vacated the part of the judgment assessing damages for the period following termination of the lease and awarding attorney's fees. View "275 Washington St. Corp. v. Hudson River Int'l, LLC" on Justia Law

Agreeing with the Board, the district court ruled that Quantum's 1996 Management Agreement with the Pueblo was null and void for lack of approval by the Secretary as required by 25 U.S.C. 81, and that it was incapable of being validated by the 2000 amendment to section 81, the application of which would be impermissibly retroactive. Applying Landgraf v. USI Film Products, the court concluded that Congress made no clear statement that it intended the 2000 amendment to apply retroactively. The court also concluded that, because the 1996 Agreement required Secretarial approval that was never obtained and the parties agreed that the Agreement would be valid without Secretarial approval under section 81 as amended, the application of the new law would give life to a null and void agreement, thereby attaching new legal consequences to it. Although the Pueblo may have voluntarily undertaken the stated duties and liabilities under the Agreement, such an agreement was null and void without Secretarial approval before 2000. Since the Secretary never approved the Agreement, any legislative validation of the duties or liabilities attached to it was impermissibly retroactive. Accordingly, the court affirmed the grant of summary judgment. View "Quantum Entertainment Ltd. v. Dept. of the Interior" on Justia Law

Plaintiff appealed from the district court's dismissal of the counts in its amended complaint directed against the Vatican State. Plaintiff alleged fraud, negligence, breach of contract, unjust enrichment, and conversion, in connection with a licensing program involving artwork and artifacts in the Vatican Library collection. The district court dismissed plaintiff's claims on the grounds of improper venue based on the forum selection clauses contained in the Sublicense Agreements. Plaintiff is a New York corporation with its principal place of business in Long Beach, New York. The Vatican State is the territory over which the Holy See of the Roman Catholic Church exercised sovereignty. The court held that the Vatican State could invoke the forum selection clauses in the sublicense agreements because the licensee and the Vatican State were "closely related" parties and it was foreseeable that the Vatican would enforce the forum selection clauses. Accordingly, the court affirmed the judgment. View "Magi XXI, Inc. v. Stato della Citta del Vaticano" on Justia Law