Justia Contracts Opinion Summaries
Giersdorf v. A & M Constr., Inc.
At issue in this case was whether the workers' compensation courts had the authority to hear a petition filed by Insured to determine whether Insurer had a duty to defend and indemnify Insured under a policy for workers' compensation insurance. Insurer moved to dismiss Insured's petition, arguing that the compensation judge did not have subject matter jurisdiction to hear the petition because it asserted a breach of contract claim rather than one arising under the workers' compensation laws. The compensation judge disagreed and denied Insurer's motion to dismiss. The workers' compensation court of appeals (WCCA) affirmed, concluding that Insured was seeking a declaration that its insurance coverage with Insurer was still "in effect," a question within the compensation judge's authority to decide. The Supreme Court affirmed, holding that the workers' compensation courts had jurisdiction to decide the issues presented in Insured's petition for declaration of insurance coverage, as the real nature of the claim was whether Insured's insurance coverage was in effect, a question that was within the authority of the compensation judge to answer. View "Giersdorf v. A & M Constr., Inc." on Justia Law
Scott Timber Co. v. United States
In 2009 the Forest Service awarded Scott contracts to remove timber on federally-owned plots during a designated period. Scott was then pursuing litigation based on delays in other contracts resulting from environmental litigation. The government therefore included provisions in the contracts at issue, authorizing suspension of the contracts to comply with court orders or for environmental reasons. The contracts provided for term adjustment, but prohibited award of lost profits, attorney’s fees, replacement costs, and similar losses. Another environmental suit arose in Oregon, resulting in an injunction that included the contracts at issue. The Forest Service suspended the contracts and began protected species surveys required by that litigation. Surveys were completed in late 2000, but the suspensions continued, due to new litigation, until 2003. In 2004-2008, Scott harvested the total contractual amount of timber. In 2005, Scott sought damages. The Claims Court found breach of an implied duty of good faith and fair dealing and that the government unreasonably delayed the surveys and continued the suspensions. The court found that Scott was entitled to $28,742 in lost profits and $129,599 in additional costs, offset by some actual profit; the government was also liable to a log-processing subcontractor, for $6,771,397 in lost profits; The Federal Circuit reversed. View "Scott Timber Co. v. United States" on Justia Law
McGair v. Am. Bankers Ins. Co. of Fla.
Plaintiffs purchased a flood insurance policy from Appellee, American Bankers Insurance Company of Florida. Their policy was issued pursuant to a federal program under which private insurers issue and administer standardized flood insurance policies (WYO companies), and all claims are paid by the government. After a flood damaged their home in Rhode Island, including the contents of their basement, Plaintiffs sought compensation. American Bankers disallowed much of the amount claimed, asserting that the contents of Plaintiffs' basement were not covered by their policy. Plaintiffs subsequently brought suit in federal court, arguing that the Declarations Page of their policy created an ambiguity as to the scope of coverage and that, under federal common law and general insurance law principles, this ambiguity should be resolved in their favor. The district court entered summary judgment in favor of American Bankers. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' claim was not remotely a claim on which a WYO company may be required to pay damages. View "McGair v. Am. Bankers Ins. Co. of Fla." on Justia Law
Contour Design, Inc. v. Chance Mold Steel Co., Ltd.
in this trade secret misappropriation and breach of contract case, defendant Chance Mold Steel Co. (Chance) appealed from a permanent injunction and from a jury award of damages. The injunction, based on a finding of contract breach, prohibited Chance from selling, displaying, manufacturing, or assisting others in manufacturing a number of ergonomic computer mouse products. The injunction barred sale of specific products that were materially identical to products Chance had previously manufactured for Contour Design, Inc. (Contour) and a new product known as the ErgoRoller. Chance challenged the scope of the injunction and contended that the jury improperly awarded lost profits damages. The First Circuit Court of Appeals (1) reversed the injunction as applied to the ErgoRoller, holding that the record did not support the finding that Chance breached the contract in producing the ErgoRoller; (2) affirmed the scope of the injunction as applied to the other enjoined products; and (3) affirmed the damages award. View "Contour Design, Inc. v. Chance Mold Steel Co., Ltd." on Justia Law
Reeder v. Wood County Energy, LLC
This case involved the duties and standard of care of an oil and gas operator under an exculpatory clause in a joint operating agreement (JOA). Based on language in the exculpatory clause in the JOA, the trial court instructed the jury to find that to find a breach of the JOA the operator's conduct must have risen to the level of gross negligence or willful misconduct. The jury found the operator, Petitioner, breached his duties under the JOA to the working interest owners. The court of appeals affirmed, holding (1) the gross negligence and willful misconduct instruction should not have been included in the charge because the case centered around a breach of contract; but (2) there was legally sufficient evidence to support the jury's findings that Petitioner breached his duty as operator when measured against the elements of breach of contract. The Supreme Court reversed, holding (1) the exculpatory clause in the JOA established the standard for the claims against Petitioner; and (2) there was legally insufficient evidence that Petitioner was grossly negligent or acted with willful misconduct. View "Reeder v. Wood County Energy, LLC" on Justia Law
Claman v. Popp
In July 2008, Appellant-Plaintiff Monica Claman purchased a house in Rock Springs, Wyoming, from Appellee-Defendant Jean Popp. In September 2008, Appellant filed an action against Popp based on subsidence-caused defects in the house. The district court entered summary judgment against Appellant on her breach of contract and negligent misrepresentation claims, and following a bench trial, it entered judgment against her on her fraudulent inducement claim. The issues on appeal were: (1) whether the trial court appropriately entered summary judgment against Appellant as to her breach of contract claim; (2) whether the trial court appropriately entered summary judgment against Appellant as to her claim for negligence/negligent misrepresentation; and, (3) whether the district court erred in its conclusions relating to the Department of Environmental Quality. Finding that the district court's summary judgment against Appellant's breach of contract and negligent misrepresentation claims were in accordance with law and undisputed facts, and that the court's findings of fact on the fraudulent inducement claim were not clearly erroneous, the Supreme Court affirmed the district court's decision. View "Claman v. Popp" on Justia Law
Baisden v. I’m Ready Productions, Inc., et al.
Plaintiff, the host of a nationally syndicated radio show and the author of several books, appealed an adverse judgment in his suit against various defendants for copyright infringement, breach of contract, and tortious interference. Defendants cross-appealed the denial of attorneys' fees. Because the court agreed that the facts of this case supported the creation of an exclusive license as to the first work at issue, and an implied nonexclusive license as to the second work at issue, the court affirmed the jury's verdict that defendants did not infringe on plaintiff's copyrights. The court rejected the remaining challenges to the district court's judgment and affirmed in all respects. View "Baisden v. I'm Ready Productions, Inc., et al." on Justia Law
Garcia v. Bridgeport
This case arose out of a motor vehicle accident caused by an underinsured motorist in which Plaintiff, an employee of defendant City (Defendant), sustained injuries while operating a private passenger motor vehicle owned by Defendant and acting within the scope of his employment. Plaintiff sought coverage for his remaining damages from Defendant pursuant to its obligation to provide underinsured motorist coverage pursuant to Conn. Gen. Stat. 38a-336(a)(2). Defendant denied Plaintiff's claim because Plaintiff's $50,000 recovery exceeded the purported $20,000 coverage limit of Defendant's plan. The trial court rendered in favor of Defendant, determining the limits of Defendant's underinsured motorist coverage in its capacity as a self-insurer to be the statutory minimum of $20,000 per person and $40,000 per occurrence. The Supreme Court affirmed, albeit under different reasoning, holding that pursuant to the statutory insurance scheme, a self-insurer is deemed to provide the minimum statutory underinsured motorist coverage of $20,000 per accident and $40,00 per occurrence for the benefit of occupants of its private passenger motor vehicles. View "Garcia v. Bridgeport" on Justia Law
LeBlanc v. Logan Hilton Joint Venture
An electrician was killed by electrocution while attempting to repair an electrical transformer at the Logan Airport Hilton Hotel (Hilton). Plaintiff, as administratrix of the electrician's estate, filed suit against, inter alia, Hilton, the architect who designed the hotel (Cambridge Seven), the consultant Cambridge Seven retained to provide electrical engineering services (Costentini), and the construction subcontractor for electrical services (Broadway), alleging negligence, gross negligence, and breach of warranty. Hilton and Broadway filed cross claims against Cambridge Seven and Cosentini for indemnification and contribution. The superior court granted the motion for summary judgment brought by Cambridge Seven and Cosentini as to the complaint and cross claims and ordered final judgment. Hilton and Broadway appealed. The Supreme Court (1) affirmed the grant of summary judgment on behalf of Cambridge Seven and Cosentini as to the cross claims brought by Hilton and Broadway for indemnification; but (2) reversed as to the cross claims for contribution. Remanded. View "LeBlanc v. Logan Hilton Joint Venture" on Justia Law
Ballard v. Roberson
Andrew Ballard worked for years crafting a plan for a marina through Warpath Development, Inc., the business he had incorporated for this purpose. He eventually sought the investment and involvement of Tim Roberson, Rick Thoennes, Rick Thoennes, III (collectively, Appellants) to help realize the idea. When the marina did not develop the way the Appellants had hoped, they began to exclude Ballard from involvement with Warpath, leading Ballard to file suit against the individual Appellants and Warpath. The circuit court found Appellants had acted oppressively to Ballard as a minority shareholder and ordered the purchase of Ballard's stock at fair market value. The court also ordered the individual Appellants to place 60,000 shares of Warpath stock in escrow. On appeal, Appellants argued that the facts do not support the court's holdings. Upon review, the Supreme Court affirmed. View "Ballard v. Roberson" on Justia Law