Justia Contracts Opinion Summaries
E.H. Turf Supply Co. v. Tavares
E.H. Turf Supply Company, Inc. filed a small-claims action against Roger Tavares, alleging that Tavares stopped payment on a check for services performed on his tractor. Tavares denied the allegations and counterclaimed for $2,500, asserting that the services were not rendered. The District Court ruled in favor of E.H. Turf Supply, awarding $1,500 plus costs. Tavares appealed to the Superior Court, arguing procedural errors and bias.The Superior Court held a de novo bench trial. E.H. Turf Supply presented testimony from its president, Erik Hagenstein, who detailed the company's repair process and confirmed that Tavares had approved and paid for the services before stopping payment. Tavares cross-examined Hagenstein and attempted to introduce invoices from other repair shops to show that the repairs were not properly done. The trial justice excluded these invoices as hearsay but allowed Tavares to testify about his experience.The Superior Court found in favor of E.H. Turf Supply, awarding $1,703.71. Tavares appealed to the Rhode Island Supreme Court, arguing that the Superior Court erred in allowing E.H. Turf Supply to present its case first, excluding his evidence, and not considering his status as a self-represented litigant.The Rhode Island Supreme Court reviewed the case and found no merit in Tavares's arguments. The Court held that E.H. Turf Supply, as the plaintiff, was correctly allowed to present its case first. The exclusion of the invoices was proper as they were hearsay, and the trial justice provided Tavares with ample opportunity to present his case. The Court affirmed the judgment of the Superior Court. View "E.H. Turf Supply Co. v. Tavares" on Justia Law
Insure Idaho v. Horn
Claudia Horn worked for Insure Idaho, LLC for over six years and signed a non-solicitation agreement prohibiting her from soliciting Insure Idaho customers. After leaving Insure Idaho to work for Henry Insurance Agency, LLC, several Insure Idaho customers followed her. Insure Idaho sought a preliminary injunction to prevent Horn and Henry Insurance from soliciting its customers, which the district court granted. The district court later found Horn in contempt for violating the preliminary injunction when another former Insure Idaho customer moved its business to Henry Insurance.The district court granted the preliminary injunction and found Horn in contempt, but did not impose any sanctions. Henry Insurance was dismissed from the contempt proceedings and awarded attorney fees. Horn appealed the contempt judgment, and both Henry Insurance and Insure Idaho cross-appealed.The Supreme Court of Idaho reviewed the case and determined that the district court erred in finding Horn in contempt, as it lacked the ability to impose any sanction. The court also found that the district court misinterpreted the term "solicitation" and that Horn's actions did not constitute solicitation under the plain meaning of the term. The court held that the district court abused its discretion by granting the preliminary injunction without adequately addressing whether Insure Idaho was likely to succeed on the merits of its claims.The Supreme Court of Idaho reversed the judgment of contempt, vacated the preliminary injunction, and remanded the case for further proceedings. The court affirmed the district court's dismissal of Henry Insurance from the contempt proceedings and awarded attorney fees to Henry Insurance. The court also awarded Horn attorney fees for the contempt trial and appellate attorney fees for both Horn and Henry Insurance. View "Insure Idaho v. Horn" on Justia Law
K7 Design Group, Inc. v. Walmart, Inc.
During the COVID-19 pandemic, K7 Design Group, Inc. (K7) offered to sell hand sanitizer to Walmart, Inc., doing business as Sam’s Club (Sam’s Club). K7 and Sam’s Club discussed and agreed upon the product, price, quantity, and delivery terms for various hand sanitizer products through email communications. K7 delivered over 1,000,000 units of hand sanitizer to Sam’s Club, which paid approximately $17.5 million. However, Sam’s Club did not collect or pay for the remaining hand sanitizer, leading to storage issues for K7.The United States District Court for the Western District of Arkansas held a jury trial, where the jury found in favor of K7 on its breach of contract claim and awarded $7,157,426.14 in damages. Sam’s Club’s motions for judgment as a matter of law and for a new trial were denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case. Sam’s Club argued that K7 failed to present sufficient evidence of an obligation to pay for the products, the jury’s verdict was against the weight of the evidence, and the district court abused its discretion in instructing the jury. The Eighth Circuit affirmed the district court’s decision, holding that the communications between K7 and Sam’s Club constituted binding orders under Arkansas’s Uniform Commercial Code (UCC). The court found that the evidence supported the jury’s verdict and that the district court did not abuse its discretion in its jury instructions or in denying Sam’s Club’s motions. The court also affirmed the district court’s award of prejudgment interest and attorney fees and costs. View "K7 Design Group, Inc. v. Walmart, Inc." on Justia Law
CBS Holdings, LLC v. Hexagon US Federal, Inc.
Hexagon US Federal, Inc. ("HexFed") leased a portion of a building, which was later sold to CBS Holdings, LLC. A dispute arose regarding the lease's renewal, leading HexFed to file a lawsuit against CBS Holdings for breach of lease. CBS Holdings counterclaimed. The Madison Circuit Court ruled in favor of HexFed on all claims and awarded costs and attorney fees to be determined later. CBS Holdings appealed, and the Supreme Court of Alabama affirmed the trial court's judgment, including the award of costs and attorney fees.After an evidentiary hearing, the Madison Circuit Court awarded HexFed $174,987.45 in costs and attorney fees. CBS Holdings appealed, arguing that HexFed's application for attorney fees was inadequately supported due to redacted descriptions of legal work and that the trial court's order lacked sufficient detail for meaningful appellate review.The Supreme Court of Alabama reviewed the case and agreed with CBS Holdings. The court found that HexFed's heavily redacted invoices did not provide enough information to determine the reasonableness and necessity of the attorney fees. The court emphasized that a trial court's order must allow for meaningful appellate review by articulating the decisions made, the reasons supporting those decisions, and how the attorney fee was calculated, considering all the Peebles factors.The Supreme Court of Alabama reversed the trial court's order and remanded the case for HexFed to provide adequate support for its application for costs and attorney fees. The trial court was instructed to accept any necessary information or evidence to confirm the requested attorney fees and to enter a detailed order showing how it calculated the amount awarded and how it considered the Peebles factors. View "CBS Holdings, LLC v. Hexagon US Federal, Inc." on Justia Law
Johnson v. City of Omaha
A resident taxpayer of Omaha challenged the City of Omaha's contract for residential solid waste collection, alleging it was an illegal expenditure of public funds and violated the Integrated Solid Waste Management Act (ISWMA). The contract, awarded to FCC Environmental Services Nebraska, LLC (FCC-Nebraska), included a yard waste sticker program where residents could purchase stickers for additional yard waste disposal.The district court for Douglas County granted summary judgment in favor of the City and FCC-Nebraska, dismissing the taxpayer's claims. The court found that the City acted within its discretion in seeking a postopening bid clarification from FCC-Spain (the original bidder) to standardize the unit price for yard waste stickers, which did not materially alter the bid or give FCC an unfair advantage. The court also determined that the yard waste sticker fee charged by FCC did not require voter approval under § 13-2020(4) of the ISWMA, as the fee was charged by and paid to the contractor, not the City.The Nebraska Supreme Court affirmed the district court's decision. It held that the City did not act in bad faith or with favoritism in seeking the bid clarification and that the clarification did not result in a material variance from FCC's original bid. The court also agreed that the voter approval requirement in § 13-2020(4) did not apply to the yard waste sticker fee, as it was governed by § 13-2020(5), which allows contractors to charge service rates without voter approval. The court concluded that the district court did not abuse its discretion in denying the taxpayer's motion to amend the complaint to add a new theory of invalidity based on the identity of the contracting party. View "Johnson v. City of Omaha" on Justia Law
Berwald V. Stan’s, Inc.
Calvin Berwald, operating Sokota Dairy, filed a lawsuit against Stan’s, Inc., a local feed mill, alleging breach of contract and breach of implied warranties. Berwald claimed that Stan’s prematurely canceled a soybean meal purchase agreement and sold him contaminated calf starter, resulting in the death of over 200 calves. Stan’s argued that the contract was canceled due to Berwald’s late payments and that the calf deaths were due to poor facilities and feeding practices.The Circuit Court of the Third Judicial Circuit in Jerauld County granted summary judgment in favor of Stan’s on the breach of contract claim, citing accord and satisfaction. The court found that Berwald’s acceptance and deposit of a check from Stan’s, which was intended to settle the dispute, discharged the claim. A jury trial on the breach of warranty claims resulted in a verdict that Stan’s breached the warranty of fitness for a particular purpose but awarded no damages to Berwald. The jury found against Berwald on the claims for breach of the implied warranty of merchantability and barratry.The Supreme Court of the State of South Dakota reviewed the case. The court affirmed the summary judgment, holding that Stan’s satisfied the requirements for accord and satisfaction under SDCL 57A-3-311. The court found no genuine issue of material fact regarding the good faith tender of the check, the existence of a bona fide dispute, and Berwald’s acceptance of the payment. The court also upheld the denial of Berwald’s motion for a new trial, finding no newly discovered evidence that would likely produce a different result and no prejudicial juror misconduct. The court concluded that the circuit court did not abuse its discretion in its rulings. View "Berwald V. Stan's, Inc." on Justia Law
Ashmus v. Coughlin
A couple contracted to buy a lakefront home with the intention of demolishing it and building a new one. They later discovered a publicly recorded sewer line running through the property, which was not listed on the seller's disclosure form. Believing the sewer line would interfere with their construction plans, they attempted to back out of the deal, leading to litigation.The trial court granted summary judgment in favor of the seller, finding that the sewer easement was publicly recorded and that the buyers had constructive notice of its existence. The court also found no evidence that the sewer line materially and adversely impacted the use or value of the property, concluding that it was not a defect requiring disclosure.The Eighth District Court of Appeals reversed the trial court's decision, holding that there was a genuine issue of material fact regarding whether the sewer line materially and adversely affected the buyers' intended use of the property and whether the seller completed the disclosure form in good faith.The Supreme Court of Ohio reversed the appellate court's judgment, reinstating the trial court's decision. The court held that the sewer line did not constitute a material defect that the seller was required to disclose on the Residential Property Disclosure Form. The court reasoned that the term "defect" implies an inadequacy or flaw, and a working sewer line in an inconvenient location does not meet this definition. Additionally, the court noted that the disclosure form requires disclosure of conditions that could inhibit an ordinary buyer's use of the property, not a specific buyer's intended use. Therefore, the seller had no duty to disclose the sewer line, and the buyers' claim of fraudulent concealment failed. View "Ashmus v. Coughlin" on Justia Law
AST & Science LLC v. Delclaux Partners SA
AST & Science LLC, a company in the satellite technology and communications business, hired Delclaux Partners SA to introduce it to registered broker-dealers for investment purposes. Delclaux introduced AST to LionTree Advisors LLC, which handled AST's Series A financing. Two contracts were involved: a Finder’s Fee Agreement between AST and Delclaux, and a separate agreement between AST and LionTree. After the Series B financing, Delclaux claimed it was owed fees from four transactions, which AST refused to pay, leading to AST suing Delclaux for breach of contract, alleging Delclaux acted as an unregistered broker-dealer.The United States District Court for the Southern District of Florida denied summary judgment on AST’s complaint and granted summary judgment to AST on Delclaux’s counterclaim. Delclaux appealed, but the appeal was voluntarily dismissed due to jurisdictional questions. The district court later held that it lacked diversity jurisdiction but claimed federal-question jurisdiction, asserting that the case involved a federal issue regarding the Securities Exchange Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s assertion of federal-question jurisdiction. The appellate court held that the breach-of-contract claim was governed by state law and did not meet the criteria for federal-question jurisdiction under the Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing test. The court found that the federal issue was not substantial enough to warrant federal jurisdiction. Consequently, the Eleventh Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it for lack of subject-matter jurisdiction. View "AST & Science LLC v. Delclaux Partners SA" on Justia Law
Helvik v. Tuscano
Sidney and Julian Helvik, who have lived on their family ranch since 1947, sold a portion of their ranch to Wesley and Karen Tuscano in 2018. In 2020, the Helviks agreed to sell the remainder of the ranch to the Tuscanos under an agreement that included a promissory note and provisions for the Tuscanos to assist the elderly Helviks with end-of-life issues. The Helviks signed a quitclaim deed, but the Tuscanos later had them sign a gift deed, which transferred the ranch without consideration. The Tuscanos never made any payments under the agreement and used the gift deed to obtain a mortgage on the ranch.The Helviks filed a complaint in the District Court of the Sixth Judicial District, Sweet Grass County, seeking to void the agreement and the gift deed, alleging undue influence and fraud. The Tuscanos counterclaimed and filed a third-party complaint against Jacqueline Conner, alleging tortious interference and abuse of process. The District Court granted summary judgment in favor of Conner on the tortious interference claim and excluded evidence of an Adult Protective Services investigation and an oral agreement to transfer land.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court's decision to rescind the agreement based on its equitable powers, noting the unique fiduciary duty in grantor-support agreements. The court found no abuse of discretion in excluding evidence of the APS investigation and the oral agreement. The court also held that the Tuscanos waived their argument regarding jury instructions on undue influence by not objecting at trial. The summary judgment in favor of Conner was upheld due to the lack of evidence of damages. The court declined to award attorney fees to Conner under M. R. App. P. 19(5). The District Court's orders and judgments were affirmed. View "Helvik v. Tuscano" on Justia Law
Brainchild Surgical Devices, LLC v. CPA Global Limited
Brainchild Surgical Devices, LLC, a medical device developer, entered into a contract with CPA Global Limited for patent renewal services. Brainchild alleged that CPA overcharged it by marking up fees beyond the actual costs and sued for breach of contract and fraud. The district court excluded Brainchild’s expert witnesses, granted summary judgment for CPA on the breach of contract claim, dismissed the fraud claim, and denied leave to amend the fraud claim.The United States District Court for the Eastern District of Virginia dismissed Brainchild’s fraud claim for lack of particularity and denied leave to amend. The court granted summary judgment for CPA on the breach of contract claim, finding that Brainchild’s theories were inconsistent with the contract’s terms. The court excluded Brainchild’s expert witnesses, David Cass and John Keogh, for offering legal conclusions and lacking qualifications.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of Cass’ testimony due to lack of qualification and improper legal conclusions. The court also affirmed the exclusion of Keogh’s testimony for failing to disclose the bases of his opinions and offering legal conclusions but reversed the decision to disqualify him based on confidential information. The court agreed with the district court that Brainchild’s pass-through cost and implied covenant of good faith theories failed to overcome summary judgment. However, the court reversed the summary judgment for CPA on the theory that CPA applied Country Charges unrelated to the required personnel, infrastructure, and third parties for renewals in particular jurisdictions. The case was remanded for further proceedings on this theory. The court also affirmed the denial of leave to amend the fraud claim. View "Brainchild Surgical Devices, LLC v. CPA Global Limited" on Justia Law