Justia Contracts Opinion Summaries

Plaintiff served as superintendent of schools in the town of North Brookfield until 2005. Plaintiff's employment contract provided that, on his retirement, Plaintiff would be reimbursed thereafter for a percentage of his health insurance premiums on an annual basis. In 2006, Plaintiff sent a request for reimbursement for a fixed percentage of the premium costs for his health insurance policy from the date of retirement. When the town refused to honor the request Plaintiff filed this action against the school committee and the town for breach of contract and specific performance of the contract. The superior court granted Plaintiff's motion for summary judgment. On appeal, Defendants argued that the obligation to reimburse Plaintiff for a percentage of his health insurance costs annually for his life signaled that Plaintiff's final employment contract was a lifetime agreement that exceeded six years in duration and therefore violated Mass. Gen. Laws 71, 41. The Supreme Court affirmed, holding that the employment contract at issue in this case was valid and enforceable even though the reimbursement clause would presumptively exceed six years, as a contract that has expired may include enforceable obligations to be performed by the parties thereafter. View "O'Neill v. Sch. Comm. of N. Brookfield" on Justia Law

An Arizona couple was injured on their motorcycle by another biker. The accident occurred in South Dakota. Because the other motorcyclist left the scene, the couple sought uninsured motorist benefits from their insurer. The couple's policy was issued in Arizona for a motorcycle registered and principally garaged in Arizona. The insurer tendered the policy's full uninsured motorist benefits of $15,000 per person. However, the couple would have recovered $25,000 per person in South Dakota had they been able to obtain the other biker's liability insurance. The circuit court declared that the terms of the Arizona insurance policy, rather than South Dakota law, governed the applicable coverage. The Supreme Court affirmed, holding that altering the terms of the parties' contracts in these circumstances was not supported by law. View "Milinkovich v. Progressive Cas. Ins. Co." on Justia Law

This appeal arose from a dispute in district court over two liens on real property: a deed of trust and a mortgage. Appellants (Insight, LLC and several other companies) are assignees of a mortgage secured by 160 acres of real property owned by Summitt, Inc., which included an 18-acre parcel Summitt purchased from Respondents Patrick and Monica Gunter. The Respondents held a deed of trust on the 18-acre parcel. Summitt defaulted on its obligations to both Insight and the Gunters. Insight filed suit naming Summitt's principals and the Gunters as defendants. The Gunters denied that their deed of trust was junior to the Insight-Summitt mortgage. The district court denied Insight's motion for summary judgment because there was an issue as to who was the initial encumbrancer. After trial, the district court found that the closing of the Gunter-Summitt deed of trust was separate and independent from the Insight-Summitt mortgage. Furthermore, the court found that the Gunters' deed of trust effectively encumbered the Gunter property at the time the transaction between Summitt and the Gunters closed. However, it found that the Insight mortgage on the combined 160-acre parcel did not create an encumbrance on the Gunter property until the Gunter-Summitt transaction closed. On appeal, Insight argued that the mortgage had priority as a matter of law because it was a purchase money mortgage that was first recorded. Upon review, the Supreme Court concluded that the district court's finding that Insight had notice of the Gunters' deed of trust was clearly erroneous. Further, the Insight-Summitt mortgage was a purchase money mortgage , and that the court erred in concluding the deed of trust took priority. Accordingly, the Supreme Court vacated the district court's judgment in this case and remanded the case for further proceedings. View "Insight LLC v. Gunter" on Justia Law

Plaintiff-Appellant Gary Duspiva, a well driller, filed suit against Defendants-Appellees Clyde and John Fillmore to recover money that he claimed was owed to him for well drilling services. The Fillmores counterclaimed, alleging Duspiva violated the Idaho Consumer Protection Act (ICPA). The matter proceeded to trial. The district court found that Duspiva's conduct violated the ICPA and granted judgment in favor of the Fillmores. Duspiva appealed to the Supreme Court. Finding no error or abuse of discretion, the Supreme Court affirmed the trial court's decision. View "Duspiva v. Fillmore" on Justia Law

The issue before the Supreme Court in this case arose from a commercial lease dispute. Boise Mode, LLC leased space in its building to Donahoe Pace & Partners, Ltd. (DPP). Timothy Pace executed a personal guarantee for the lease. During the term of the lease, Boise Mode remodeled part of the building for another tenant. After raising concerns to Boise Mode about the adverse effects of the construction to its business, DPP eventually stopped paying rent and vacated the premises prior to the end of the lease. Boise Mode then brought an action against DPP, alleging breach of contract, and against Pace for breaching the guarantee. DPP counterclaimed, alleging that the disruption caused by the construction constituted breach of contract and constructive eviction. After Boise Mode moved for summary judgment on all claims and counterclaims, DPP requested a continuance to complete discovery. The district court denied DPP's motion and ultimately granted Boise Mode's motion for summary judgment. DPP appealed the grant of summary judgment as well as the district court's denial of its request for a continuance. Upon review, and finding no error, the Supreme Court affirmed. View "Boise Mode, LLC v. Donahoe Pace" on Justia Law

The issue before the Supreme Court in this case involved the enforceability of a binding arbitration clause included within a debt adjustment contract. The trial court denied the defendant's motion to compel arbitration, ruling that the motion was untimely and that the binding arbitration clause was unconscionable. Upon review of the trial court record and the clause at issue, the Supreme Court affirmed the trial court's holding that the clause was unconscionable, which then required the Court to decide whether this conclusion as to the validity of the binding arbitration clause is preempted by the Federal Arbitration Act (FAA). Finding no preemption, the Court affirmed. View "Gandee v. LDL Freedom Enters., Inc." on Justia Law

Glassman is a car dealer in Southfield, Michigan and an authorized Kia dealer, under an Agreement that states that Glassman’s rights are not exclusive. Glassman agreed to assume certain responsibilities in its Area of Primary Responsibility, an area undefined in the Agreement, but agreed “that it has no right or interest in any [Area of Primary Responsibility] that [Kia] may designate” and that “[a]s permitted by applicable law, [Kia] may add new dealers to … the [Area of Primary Responsibility].” Michigan’s Motor Dealers Act grants car dealers certain limited territorial rights, even when the dealer has a nonexclusive franchise, and requires manufacturers to provide notice to an existing dealer before establishing a new dealer within a certain distance of the existing dealer’s location. Receipt of notice gives the existing dealer a cause of action to challenge the proposed new dealer. Kia and Glassman entered into their Agreement in 1998, when the distance for notice was 6 miles. A 2010 amendment increased the distance to 9 miles. The district court found that the parties did not agree to comply with the 2010 Amendment and that the 2010 Amendment is not retroactive. The Sixth Circuit affirmed, holding that the 6-mile distance applies. View "Kia Motors Am., Inc. v. Glassman Oldsmobile Saab Hyundai, Inc." on Justia Law

Gerald Kirchner accidentally shot and killed Robbie Bragg while both men were working for Grimmett Enterprises (Grimmett). Kirchner's mother, Barbara Surbaugh, filed a complaint against Bragg and Grimmett. The parties settled, after which Defendants assigned all claims they might have against their respective insurers for refusing to provide a defense and coverage. Thereafter, Surbaugh filed a declaratory judgment action against Grimmett's insurer, American States. Both parties filed motions for summary judgment. At issue was whether an employee exclusion in the policy was ambiguous and whether the exclusion had been brought to the attention of Grimmett. The circuit court denied the motions. After a jury trial, the circuit court concluded that the employee policy exclusion was unenforceable because the exclusionary language had not been brought to the attention of Grimmett. The Supreme Court reversed, holding that summary judgment should have been granted in favor of American States, as American States established at the summary judgment stage that no material issue of fact was in dispute as to the exclusion being unambiguous and disclosed to Grimmett. Therefore, the exclusion was enforceable. View "Am. States Ins. Co. v. Surbaugh" on Justia Law

Kristy Johnston, Judy Olsen, and their mother, Joyce Johnston, owned real property as tenants in common. Joyce left her one-third interest in the property to Kristy when she died. Kristy sent a letter to Judy in 2009 in which she offered to buy Judy's interest in the property or to sell her interest to Judy. Judy accepted Kristy's offer to sell. Kristy subsequently attempted to reject Judy's acceptance and revoke her offer to sell. Judy filed a complaint against Kristy. The court granted Judy's motion for summary judgment, determining that the letters exchanged between Judy and Kristy had created an enforceable contract that satisfied the statute of frauds. The Supreme Court affirmed, holding that the district court properly concluded that the parties' exchange of letters created an enforceable contract. View "Olsen v. Johnston" on Justia Law

Defendants in this suit included the St. Labre Indian Education Association, Inc. and the St. Labre Home for Indian Children and Youth (collectively, St. Labre). After St. Labre experienced a decrease in government funding, St. Labor began a fundraising campaign that NCT asserted resulted in millions of dollars donated to St. Labre through efforts that marketed the plight and need of NCT. NCT filed suit against Defendants alleging (1) St. Labre's fundraising system created a constructive trust on behalf of NCT and St. Labre wrongfully converted those funds to its own use, thus unjustly enriching itself; (2) contract and fraud type issues; and (3) St. Labre unconstitutionally committed cultural genocide against NCT. The district court dismissed all of NCT's motions. The Supreme Court (1) reversed the district court's grant of summary judgment on NCT's claim for unjust enrichment and the imposition of a constructive trust that may arise from St. Labre's fundraising activities after 2002; (2) reversed the district court's grant of summary judgment regarding St. Labre's fundraising activities before 2002; and (3) affirmed the court's grant of summary judgment on all of NCT's remaining claims. View "N. Cheyenne Tribe v. Roman Catholic Church" on Justia Law