Justia Contracts Opinion Summaries

Max and Glenna Overbey recovered judgments against Chad Franklin National Auto Sales North, LLC (National) and Chad Franklin (Franklin) for fraudulent representations in violation of the Missouri Merchandising Practices Act made in connection with National's sale of a vehicle to the Overbeys. Franklin appealed, and the Overbeys appealed the trial court's reduction of the punitive damage verdict as required by statute. The Supreme Court affirmed, holding (1) the award against Franklin was fully supported by the evidence; and (2) the limit of punitive damages did not violate the Overbeys' constitutional rights or the separation of powers doctrine.

This case stemmed from the judicial sale of a condominium owned by Petitioner and conducted by two court-appointed trustees that were employed by a law firm (collectively, Respondents). Following the sale, Petitioner filed a complaint, alleging breach of fiduciary duty involving actual fraud and breach of fiduciary duty involving constructive fraud by the trustees and alleging vicarious liability by the law firm. The trial judge granted Respondents' motion to dismiss, concluding that Respondents were entitled to qualified judicial immunity for their actions in connection with the sale. The court of special appeals (1) reversed with regard to Petitioner's allegations of actual fraud, and (2) affirmed with regard to the other causes of action on grounds of qualified judicial immunity. The Supreme Court affirmed in part and reversed in part, holding that Respondents were not entitled to absolute judicial immunity, and the concept of qualified public official immunity was inapplicable to the circumstances of this case.

Plaintiff divorced his wife (Wife) after discovering she had had an extramarital affair with Defendant and had conceived a child (Child) with him. After Plaintiff and Wife divorced, Plaintiff brought an action against Defendant, seeking damages on claims of nondisclosure, misrepresentation, and unjust enrichment. Specifically, Plaintiff sought reimbursement from Defendant for the costs he had expended in raising Child from her birth until his divorce from Wife, when Child was almost fifteen years old. The trial court concluded that although Defendant was Child's biological father, the doctrine of equitable estoppel and public policy concerns precluded Plaintiff from pursuing his claims for reimbursement and denying his paternity. The Supreme Court reversed the judgment of the trial court, holding that the court improperly found that Plaintiff was equitably estopped from pursuing his claims because there was insufficient evidence of financial harm to Child, which is required to establish the element of detrimental reliance in a case involving a denial of paternity.

In a bankruptcy adversary proceeding, Capco brought claims of fraud and various business torts against Ryder, Tana, TRT, and Tristone. The claims arose out of a transaction in which Capco purchased from Tana certain oil and gas reserves located in the Gulf of Mexico (the Properties). The bankruptcy court granted summary judgment in favor of Ryder, Tana, TRT, and Tristone and dismissed the claims. The court held that Capco failed to present evidence to demonstrate a genuine issue of material fact about whether Ryder was contracted to provide an independent reevaluation of the Properties and advice at the meeting regarding Capco's decision to close on the Properties. The court also held that because the purchase and sale agreement contained a clear intent to disclaim reliance, the lower courts correctly held that Capco was unable to claim fraudulent inducement based on the prior representations of Tana, TRT, and Tristone. Accordingly, the judgment was affirmed.

The trial court granted summary judgment to Defendants-Appellees Seymour Law Firm, R. Thomas Seymour and Scott A. Graham, based on the legal theory that its failure to enforce an attorney's lien within one year after it became aware of a settlement precluded Plaintiff-Appellant Gina Cowley from enforcing a contract she held with co-counsel. Specifically, the issue before the Supreme Court was whether the expiration of the lien prohibited Plaintiff's lawyer from suing her co-counsel for breach of contract over the distribution of attorney fees from the settlement of the underlying case. Upon review, the Court held that the applicable one-year statute of limitations did not preclude a lawsuit arising over a contract dispute between Plaintiff's lawyers. The case was reversed and remanded for further proceedings.

This appeal involved Continental's pursuit of a breach of contract claim against Thorpe in Thorpe's Chapter 11 bankruptcy proceeding. The district court affirmed the bankruptcy court's order denying Continental's motion to compel arbitration and disallowing its claim. The court held that the bankruptcy court had discretion not to enforce the arbitration clause at issue and that the bankruptcy court did not abuse its discretion in denying Continental's motion to compel arbitration. The court also held that the bankruptcy court did not abuse its discretion in declining to give Continental further opportunity for discovery and Thorpe could not contract away its right to avail itself of the protections of 524(g) of the Bankruptcy Code. Accordingly, the lower courts correctly disallowed Continental's claim.

This case involved a dispute between Insured and Insurer regarding underinsured motorist benefits. The district court denied Insurer's motion for summary judgment and entered judgment in favor of Insured with interest running from the date Insured filed his action against Insurer. Insured filed a motion to modify the judgment, asking the court to amend the judgment to start the running of interest from the date Insured filed his action against the original tortfeasors. The district court granted the motion and modified the judgment. The court of appeals affirmed. The Supreme Court (1) found that the order denying Insurer's motion for summary judgment was not reviewable; (2) vacated the court of appeals; (3) affirmed the district court's judgment required Insurer to pay its underinsured motorist limit to Insured; and (4) reversed the part of the judgment awarding interest from the date Insured filed the original action against the tortfeasors, holding that Insured failed to timely file his posttrial motion and that the district court erred when it considered the motion. Remanded.

Plaintiffs, David and Barbara Smith, asserted various claims arising out of the construction of their home against Defendants, Donald L. Mattia, Inc. (DLM), Donald Mattia, and Barbara Joseph (Barbara). The Chancery Court (1) granted Defendants' motion for summary judgment on (i) Plaintiffs' breach of contract claim and (ii) Plaintiffs' civil conspiracy claim; (2) denied Defendant's motion for summary judgment on (i) Plaintiffs' claim for misappropriation of Plaintiffs' backfill and money paid to DLM that was not applied to their project and (ii) Plaintiffs' claim that Defendants fraudulently induced Plaintiffs to purchase excess lumber and misappropriated $8,836 in connection with the purchase of excess lumber; (2) granted Plaintiffs' motion for summary judgment, as Defendants did not articulate a viable cause of action in their counterclaim; and (3) denied Barbara's motion for Chan. Ct. R. 11 sanctions where there was no evidence that Plaintiffs' attorney did not have a good faith belief in the legitimacy of the claims asserted against Barbara.

Appellee Wayne Manning told Appellant Diane Roberson he would give her his share of their jointly purchased mobile home. Without her knowledge, he then transferred title of the mobile home to his name only and sold it to co-Appellee Dennis Wilson. Wilson attempted to terminate Roberson's tenancy in the mobile home. Roberson filed suit in the superior court to be declared the owner of the home. The court concluded that Manning did not give his share of the home to Roberson and that Wilson was a good-faith purchaser and therefore the owner. Roberson appealed, arguing that she is the owner because Manning's gift to her was valid and the sale to Wilson was invalid. Upon review, the Supreme Court vacated the superior court's conclusion that Manning did not give Roberson the home. The Court also vacated the superior court's determination that Wilson was a good-faith purchaser. The case was remanded for additional findings.

Plaintiffs-Appellants Randolph Farber, Scott Becker, and Critter Clinic (Farber) alleged that the Manager of the Defendant-Respondent State Insurance Fund (SIF or "the Fund") failed to comply with I.C. 72-915, which provides the means by which the SIF Manager may distribute a dividend to policyholders. The district court determined that the gravamen of Farber's claim implicated the statute and held that the three-year statute of limitation provided by I.C. 5-218(1) barred all claims that accrued prior to July 21, 2003. Farber timely appealed. Upon review, the Supreme Court held that the five-year statute of limitation in I.C. 5-216 applied to Farber's claim. Therefore, the Court reversed the trial court's decision and remanded the case for further proceedings.