Justia Contracts Opinion Summaries
Bd. Of Trs. of Internal Improvement Trust Fund v. Am. Educ. Enters., LLC
In this contract dispute, Respondent filed an action against Petitioner, claiming negligent misrepresentation, fraud in the inducement, unjust enrichment, and reformation of the contract. During discovery, Petitioner propounded to Respondent a request for the production of documents, seeking, inter alia, corporate financial documents, tax returns, budgets, and auditor's reports. Respondent objected to the request as overbroad, unduly burdensome, and irrelevant. Petitioner, in turn, moved to compel Respondent to provide the requested documents. The trial court granted Petitioner's motion and ordered Respondent to produce the requested items. Respondent petitioned the court of appeal for a writ of certiorari. The court of appeal quashed the order compelling production, holding that the order of the trial court compelling production was overbroad. The Supreme Court quashed the decision of the court of appeals, holding (1) the basis stated for certiorari relief was incorrect and in express conflict with numerous Florida decisions; and (2) because the requested information was relevant to the disputed issues and Respondent had not demonstrated irreparable harm through its disclosure, the information was discoverable. View "Bd. Of Trs. of Internal Improvement Trust Fund v. Am. Educ. Enters., LLC" on Justia Law
Posted in:
Contracts, Florida Supreme Court
Cambridge Integrated Services v. Concentra Integrated Services
Cambridge appealed the district court's grant of summary judgment in favor of Concentra. Cambridge and Concentra owed each other contractual duties of defense and indemnification. Cambridge and a subsidiary of Concentra were later named as defendants in a state court lawsuit. Concentra settled and obtained a release that benefited Cambridge to the extent of Concentra's indemnification obligation. However, Concentra rejected Cambridge's tender of defense. Cambridge filed suit in federal court seeking a declaratory judgment that Concentra owed it contractual defense and indemnification for the costs that Cambridge incurred in settling the state-court litigation. The court affirmed summary judgment of the district court dismissing Cambridge's claims against Concentra for indemnification, but reversed summary judgment with respect to Concentra's duty to defend. View "Cambridge Integrated Services v. Concentra Integrated Services" on Justia Law
Posted in:
Contracts, U.S. 5th Circuit Court of Appeals
Caldas v. Affordable Granite & Stone, Inc.
At issue in this case was whether Appellants, who were employees of a contractor that performed work pursuant to a municipal contract with the City of Minneapolis, may recover for the contractor's alleged breach of a prevailing wage provision in the contract. Appellants brought this action against the contractor, alleging that the contractor failed to pay them the prevailing wage in breach of the contract with the City, that the breach of the contract by the contractor violated state wage statutes, and that the contractor was unjustly enriched as a result. The district court granted the contractor's motion for summary judgment, concluding that Appellants were not intended third-party beneficiaries and that without a viable claim for breach of contract, Appellants' other claims failed. The court of appeals affirmed. The Supreme Court affirmed, concluding that Appellants were not intended third-party beneficiaries of the contract and that Appellants' other claims lacked merit. View "Caldas v. Affordable Granite & Stone, Inc." on Justia Law
Bangor Gas Co., LLC v. H.Q. Energy Servs. (U.S.) Inc.
A pipeline owner and a natural gas supplier entered into a contract for the transportation of the supplier's natural gas. The parties later became embroiled in a dispute and submitted their dispute to binding arbitration. After the arbitrators issued a decision largely favorable to the supplier, the pipeline owner sought to vacate the decision in the district court. The district court entered judgment in favor of the supplier. The First Circuit Court of Appeals affirmed, holding (1) the arbitration panel's decision to make the pipeline owner by for the lateral costs was not in manifest disregard of the law; and (2) the panel did not compromise on the matter of the destination-end heating costs, which it imposed on the supplier for the future but declined to make the ruling retroactive; and (3) even assuming that the arbitrators committed misconduct by considering in their decision two documents among the three that the panel attached to its written decision, the misconduct could not have been prejudicial. View "Bangor Gas Co., LLC v. H.Q. Energy Servs. (U.S.) Inc." on Justia Law
Grinnell Mut. Reins. Co. v. Haight
Haight purchased an insurance policy that included underinsured motorist coverage for the named insured (him) and any family members. After his teenage daughter Nicole was injured while riding in a car driven by an acquaintance whose insurance did not fully compensate her, she made an underinsured motorist claim on her father’s policy. The insurance company maintained that Nicole is not entitled to coverage because she was not riding in a vehicle listed on her father’s policy when she was hurt. The district court ruled in favor of Haight. The Seventh Circuit affirmed. The policy provides underinsured motorist coverage to the named insured and his family members that does not require that they be occupying a vehicle listed on the policy during the accident. View "Grinnell Mut. Reins. Co. v. Haight" on Justia Law
Turner v. Wells Fargo Bank, N.A.
James Turner and Julie Viers opened a line of credit with Wells Fargo Bank and granted Wells Fargo a deed of trust on property they owned as security for the line of credit. Later, John Turner, Christina Turner, and Sandy Couch (the John Turners) purchased the property. Julie and James paid off the entire outstanding balance under the credit line agreement using the proceeds from the sale of the property to the John Turners, but Julie subsequently borrowed $169,090 under the credit line agreement secured by the property. Thereafter, Wells Fargo refused to release the deed of trust. The John Turners then filed a complaint to quiet title to the property. The district court granted Wells Fargo's motion for summary judgment, concluding that the John Turners could not enforce the terms of the credit line agreement because they were not intended beneficiaries of the agreement. The Supreme Court affirmed, holding that the district court correctly concluded (1) the John Turners were not entitled to judgment requiring Wells Fargo to release the deed of trust the bank held on the property; and (2) the John Turners failed to establish prima facie claims of promissory or equitable estoppel. View "Turner v. Wells Fargo Bank, N.A." on Justia Law
Milford-Bennington R.R. Co. v. Pan Am Rys., Inc.
Milford-Bennington Railroad Company, Inc. (MBR) appealed an award of summary judgment to Pan Am Railways, Inc., Boston and Maine Corporation, and Springfield Terminal Railway Company (collectively, "Pan Am") in a dispute arising from Pan Am's actions under a contract to provide MBR with access to Pan Am's railroad tracks. The district court held that Pan Am did not breach its duty of good faith and fair dealing when it exercised its contractual right to exclude an MBR employee from its trackage for violating a safety rule. The First Circuit Court of Appeals affirmed, holding that even if Pan Am was bound by a duty of good faith and fair dealing when exercising its right to exclude the employee from its trackage, Pan Am did not breach that duty. View "Milford-Bennington R.R. Co. v. Pan Am Rys., Inc." on Justia Law
Posted in:
Contracts, U.S. 1st Circuit Court of Appeals
Kohanowski v. Burkhardt
Defendant Jessica Burkhardt appealed a district court judgment that awarded damages to Plaintiff Jon Kohanowski for the unpaid balance of a loan and ordered Defendant to pay costs and attorney fees. Defendant was engaged to marry Shaun Kohanowski, Plaintiff's brother. In 2006, Shaun and Defendant were planning to purchase a home. Shaun Kohanowski contacted Jon Kohanowski, who agreed to lend the couple money to help buy the home. Jon Kohanowski alleged that Defendant was in the room and overheard Shaun's side of the telephone conversation during which the brothers discussed the loan. Plaintiff contended the terms of the loan required Defendant and Shaun to repay the loan. Plaintiff wired $675 to Shaun and Defendant's bank to start the appraisal process and sent a check for $9,325 payable to Shaun and Defendant. Only Shaun endorsed the check, and he deposited the proceeds into a joint checking account he shared with Defendant. In early 2007, Defendant signed two checks for $215 each drawn on the joint account and payable to Plaintiff. Defendant and Shaun subsequently called off their engagement, and no further payments were made on the loan. In September 2010, Shaun e-mailed a "Letter of Intent" to Plaintiff acknowledging the debt, promising to pay one-half of the remaining debt with interest, and promising to assist Plaintiff in collecting the remaining one-half of the debt from Defendant. In October 2010, Plaintiff sued Defendant in small claims court for one-half of the remaining debt and a portion of the travel costs he had allegedly incurred attempting to collect the debt. Defendant removed the action to district court and demanded a jury trial. After a trial, the jury awarded Plaintiff $6,641.29, one-half of the remaining debt plus interest. Defendant moved for judgment as a matter of law, a new trial, or relief from the judgment. The district court impliedly denied Defendant's motions, instead entering an order awarding Plaintiff costs and attorney fees. Upon appeal, the Supreme Court reversed, concluding the alleged oral loan agreement was barred by the statute of frauds.
View "Kohanowski v. Burkhardt" on Justia Law
Bldg. Materials Corp. of Am. v. Bd. of Educ.
For some years, the Board of Education of Baltimore County belonged to a governmental group purchasing consortium, which competitively bid a roofing services contract on behalf of its members. The Board relied on that contact to fulfill its needs for roofing repair services. Appellant Building Materials Corporation of America, a nationwide manufacturer of roofing materials, questioned the Board's authority for that practice under the pertinent statutes. The circuit court granted summary judgment in favor of the Board. The Court of Appeals affirmed, holding that when viewed in the context of the entire education law and regulations promulgated under that law, the competitive bidding statute did not bar the Board from using its membership in an intergovernmental purchasing consortium for the procurement of roofing repair services. View "Bldg. Materials Corp. of Am. v. Bd. of Educ." on Justia Law
Portercare Adventist Health System v. Lego
Respondent Robert Lego admitted his wife to Porter Hospital's emergency room. She stayed there for approximately two months. The Legos' insurance provider notified Respondent in writing that it would stop covering Mrs. Lego's hospital care after six weeks. Respondent disputed the insurer's position and refused to discharge his wife from the hospital after six weeks. The hospital followed the insurer in notifying Respondent the insurance coverage for Mrs. Lego would end, and that the Legos would be responsible for any uncovered charges. In an effort to recoup those charges Respondent refused to pay, the hospital sued on the grounds of unjust enrichment with recovery in quantum meruit. Respondent moved to dismiss, arguing that the action was barred by a general statute of limitations codified in section 13-80-103.5(1)(a) C.R.S. (2011). The trial court denied the motion; the appellate court reversed, finding the trial court erred in determining the amount the insurance company did not pay was liquidated or determinable damages within the meaning of the statute. The Supreme Court reversed the appellate court, interpreting section 13-80-103.5(1)(a) C.R.S. (2011) to mean its six-year limitations period applied in this case, particularly when the amount owed was ascertainable either by reference to the agreement, or by simple computation using extrinsic evidence.
View "Portercare Adventist Health System v. Lego" on Justia Law