Justia Contracts Opinion Summaries
Meador v. Total Compliance Consultants, Inc.
Plaintiff was employed by a staffing company and had been contracted to work at Gates Rubber Company (Gates) when he suffered an injury to his arm and hand, including the severing of fingers. Plaintiff alleged that Total Compliance Consultants, Inc. (TCC) had contracted with Gates to consult on safety-compliance issues and that TCC either breached its contract or was negligent. The circuit court dismissed the complaint, concluding that Plaintiff was a third-party beneficiary of the contract between TCC and Gates but that TCC was not negligent and did not breach its contract. The Supreme Court affirmed, holding that Plaintiff's points on appeal were either not appealable or lacked merit. View "Meador v. Total Compliance Consultants, Inc." on Justia Law
City of Malvern v. Jenkins
Plaintiffs filed a complaint alleging that, without their knowledge, the City had erected a sewer line across Plaintiffs' property. Plaintiffs contended that in doing so, the City damaged a water pipe owned by Plaintiffs and that the damaged culvert was the proximate cause of three washouts on their property. Plaintiffs alleged causes of action for negligence and inverse condemnation. The City filed a motion for summary judgment, which the circuit court denied. The City appealed, arguing that the circuit court mischaracterized Plaintiffs' claim as based on contract, rather than tort, and in so doing denied the City the immunity to which it was entitled. The Supreme Court reversed, holding (1) the circuit court erred in finding Plaintiffs' negligence claim sounded in contract rather than tort; and (2) the City was entitled to statutory immunity as to the tort cause of action. View "City of Malvern v. Jenkins" on Justia Law
Levy Gardens Partners 2007, LP v. Lewis Title Ins. Co.
Levy Gardens appealed the district court's decision ordering Commonwealth to pay Levy Gardens pursuant to Levy Gardens' title insurance policy with Commonwealth. The court held that the district court did not err in concluding that Levy Gardens had coverage under the insurance policy and that Levy Gardens did not violate the conditions of the policy in a manner prejudicial to Commonwealth. The district court did not err in concluding that the insurance policy provided coverage for only the diminution in value of title to the property resulting from the zoning encumbrance. The district court's findings that Commonwealth's actions were not arbitrary and capricious and Commonwealth made its assertions in good faith were reasonable and supported by the record. Therefore, the court held that the district court did not manifestly err by declining to impose penalties to Commonwealth. Accordingly, the court affirmed the judgment. View "Levy Gardens Partners 2007, LP v. Lewis Title Ins. Co." on Justia Law
Clinton Growers, et al v. Pilgrims Pride Corp.
The Growers filed claims against PPC seeking promissory estoppel relief, alleging that the company's oral promises of a long-term relationship induced them to invest in chicken houses. The district court affirmed the bankruptcy court's grant of summary judgment for PPC on the ground that the written contracts between PPC and the Growers barred the alleged oral promises because the contracts addressed the same subject matter as the Growers' claims. Because the court found that this contract bar precluded the Growers' promissory estoppel claims, the court did not address the other issues raised on appeal and therefore, affirmed the judgment. View "Clinton Growers, et al v. Pilgrims Pride Corp." on Justia Law
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Contracts, U.S. 5th Circuit Court of Appeals
Wash. State Major League Baseball Stadium v. Huber, Hunt & Nichols-Kiewit Constr. Co.
This action stemmed from a contract for construction of a baseball stadium and home field for the Seattle Mariners baseball team. In its first trip to the Supreme Court, "Washington State Major League Baseball Stadium Public Facilities District v. Huber, Hunt & Nichols-Kiewit Construction Company," (202 P.3d 924 (2009) (PFD I)), the Court held that the statute of limitations did not bar the owner’s suit against the general contractor because the action was brought for the benefit of the State, and therefore the exemption from the statute of limitations set out in RCW 4.16.160 applied. This case raised questions about whether the construction statute of repose barred suit against the general contractor and, if not, whether the general contractor may pursue third party claims against two of its subcontractors. The trial court granted summary judgment of dismissal in favor of the general contractor and the subcontractors on statute of repose grounds. Upon review of the matter, the Supreme Court reversed the trial court: "the statute of repose does not bar suit against the general contractor. In accord with several provisions in the subcontracts, the subcontractors are subject to liability to the same extent that the general contractor may be liable for any defective materials or work under the subcontracts. Thus, the trial court erred in holding that the statute of repose bars Hunt Kiewit’s third party claims against the subcontractors."
View "Wash. State Major League Baseball Stadium v. Huber, Hunt & Nichols-Kiewit Constr. Co." on Justia Law
Heubel Materials Handling Co. v. Universal Underwriters Ins. Co.
Heubel and Raymond appealed the district court's grant of summary judgment in favor of Universal on Heubal's claim for coverage under a Universal insurance policy. The district court held that Heubel's breach of a cooperation clause in the Universal policy absolved Universal of the duty to defend or provide coverage for a products liability lawsuit against Heubel. Because no reservation of rights or conflict of interest entitled Heubel to select its own counsel while continuing to enjoy the coverage benefits of the Universal policy, Heubel breached the policy by refusing to allow Universal to control the defense. Because nothing in the Universal policy or the Raymond indemnification program precluded a third-party indemnification claim by Universal against Raymond in the Harris suit, Universal suffered substantial prejudice from Heubel's refusal to allow Universal to control the defense. As a result, Universal was justified in denying coverage based on Heubel's breach of the cooperation clause. Accordingly, the court affirmed the judgment. View "Heubel Materials Handling Co. v. Universal Underwriters Ins. Co." on Justia Law
Kramer, et al v. Toyota Motor Corp., et al
Plaintiffs, Prius owners, brought a putative class action suit against Toyota, alleging that they experienced defects in their anti-lock brake systems (ABS), resulting in increased stopping distances. On appeal, Toyota sought review of the district court's denial of their motion to compel arbitration. The court concluded that Toyota could not compel plaintiffs to arbitrate their claims. The district court had the authority to decide whether Toyota, a nonsignatory to the Purchase Agreement, could compel arbitration. The court discerned no reason that plaintiffs should be equitably estopped from avoiding arbitration in this case. Accordingly, the court affirmed the judgment. View "Kramer, et al v. Toyota Motor Corp., et al" on Justia Law
Duckworth v. Allianz Life Ins. Co., et al
Allianz appealed the district court's grant of judgment in favor of plaintiff on his claim that Allianz miscalculated the monthly benefit to which he was entitled under a long-term disability insurance policy. Allianz contended that the district court improperly interpreted the offset provision of the policy. The court concluded that the policy's offset provision was not afflicted with ambiguity and the district court should not have resorted to canons of construction to determine the unwritten intent of the provision. Accordingly, the court reversed and remanded for entry of judgment in favor of Allianz. View "Duckworth v. Allianz Life Ins. Co., et al" on Justia Law
Travelers Prop. Cas. Co. of Am. v. Manitowoc Co., Inc.
A construction crane owned and operated by a construction company (Jacobsmeyer) fell on a building. Jacobsmeyer's insurer (Travelers) reached a settlement agreement with the designer and manufacturer of the crane (Grove) wherein Grove agreed to pay Jacobsmeyer and Travelers (hereinafter referred to collectively as Jacobsmeyer) for a majority of their remaining losses associated with the accident. Jacobsmeyer subsequently sued Grove and its parent company (hereinafter referred to jointly as Manitowoc) for breach of the settlement agreement. Manitowoc filed third-party petition claims for contribution and/or indemnity against U.S. Steel, alleging that U.S. Steel's predecessor-in-interest provided the faulty steel for the crane. The trial court dismissed Manitowoc's third-party petition with prejudice because Manitowoc failed to satisfy pleading requirements where it did not admit its own liability as a joint tortfeasor in its third-party petition. The Supreme Court reversed, holding that a party seeking contribution or indemnity need not admit its own fault in its third-party petition but rather can deny liability in its answer to the plaintiff's petition and assert in its third-party petition that if it is liable to the plaintiff, then the third-party defendant is liable to it. Remanded. View "Travelers Prop. Cas. Co. of Am. v. Manitowoc Co., Inc." on Justia Law
Anastasia v. Gen. Cas. Co. of Wis.
Plaintiff and her husband were traveling in Plaintiff's automobile when Tortfeasor collided with the automobile, causing significant injuries to Plaintiff and her husband. At the time of the collision, the motor vehicle driven by Tortfeasor was underinsured. Plaintiff submitted a claim for underinsured motorist coverage to her Insurer. Insurer refused to provide coverage in light of Plaintiff's recovery under a settlement agreement with Tortfeasor. Subsequently, Plaintiff brought this action seeking underinsured motorist coverage under her policy. The trial court granted summary judgment for Insurer, concluding Insurer was entitled to a setoff equal to the amount of the entire settlement. The Supreme Court affirmed, holding that Insurer was entitled to a reduction of its limits of liability for underinsured motorist coverage by an amount equal to the sum of punitive damages paid to Plaintiff. View "Anastasia v. Gen. Cas. Co. of Wis." on Justia Law