Justia Civil Procedure Opinion Summaries

Golden View Ready-Mix, LLC (Golden View) supplied concrete to Grangaard Construction, Inc. (Grangaard) for a bridge project. Golden View alleged that Grangaard failed to pay for the concrete, breached the implied obligation of good faith and fair dealing, and committed fraud. A jury found in favor of Golden View on the breach of contract and good faith claims, awarding damages and punitive damages, but found no liability for fraud. Grangaard appealed the punitive damages award and the decision to submit the fraud issue to the jury.The Circuit Court of the First Judicial Circuit, McCook County, South Dakota, presided over the case. Grangaard moved for partial summary judgment on the fraud claim, arguing there was no independent tort duty outside the contract. The court denied this motion, allowing the fraud claim to proceed. During the trial, the court permitted the jury to consider punitive damages based on the breach of the implied obligation of good faith, despite Grangaard's objections.The Supreme Court of the State of South Dakota reviewed the case. The court determined that punitive damages are only recoverable for breaches of obligations not arising from a contract, as per SDCL 21-3-2. The court found that the implied obligation of good faith arises from the contract itself and does not constitute an independent tort that could support punitive damages. Consequently, the court vacated the punitive damages award. However, the court affirmed the lower court's judgment in all other respects, concluding that the error regarding punitive damages did not affect the jury's decision on the breach of contract and good faith claims. View "Goldenview Ready-Mix, LLC v. Grangaard Construction, Inc." on Justia Law

The Nelson Estate claimed an interest in a coin shop and alleged conversion of its property. Dr. Earl Nelson had provided funds for the business, resulting in a 50% ownership interest, which was confirmed by William Tinkcom. After Dr. Nelson's death in 2013, Tinkcom continued to operate the business and assured Nelson's heirs of their 50% interest. Tinkcom died in 2022, and the business was sold to Eddie Welch without including the Nelson Estate in the final agreement. The Nelson Estate sued the Tinkcom Estate, Welch, and Mere Coin Company, LLC, for breach of contract, unjust enrichment, and other claims, including conversion of valuable coins and collectibles.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota, granted the defendants' motion for judgment on the pleadings, concluding that the statute of limitations barred all claims. The Nelson Estate argued that the statute of limitations had not expired and that equitable estoppel or fraudulent concealment should prevent the statute of limitations defense.The Supreme Court of South Dakota reviewed the case and affirmed the circuit court's determination that the first six business interest claims accrued upon Dr. Nelson's death in 2013. However, the court reversed the dismissal of these claims because the circuit court did not address the Nelson Estate's defenses of equitable estoppel and fraudulent concealment. The court also reversed the dismissal of the tortious interference and civil conspiracy claims, as these claims arose from the 2022 sale of the business. Lastly, the court reversed the dismissal of the conversion claim, noting that the record did not establish when the conversion occurred or when the Nelson Estate became aware of it. The case was remanded for further proceedings. View "Nelson v. Tinkcom" on Justia Law

The case involves a dispute between the former owner-operator of a professional baseball franchise in Puerto Rico and the league, its president, and other franchise owners. The plaintiffs allege that the defendants conspired to force the former owner to relinquish control of the franchise, violating the Sherman Act, a federal civil rights statute, and various Puerto Rico laws. The plaintiffs claim that the defendants' actions were in retaliation for the former owner's public criticism of the conditions at the team's stadium and his proposal to move the team to another municipality.The United States District Court for the District of Puerto Rico dismissed the plaintiffs' Sherman Act claims, citing the "business of baseball" exemption. The court also ruled that the plaintiffs' claims under Puerto Rico's antitrust and fair competition laws were preempted by federal law. Additionally, the court dismissed the plaintiffs' federal civil rights claim on res judicata grounds, based on a prior judgment from the Superior Court of San Juan. The court then declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claim.The United States Court of Appeals for the First Circuit affirmed the dismissal of the Sherman Act claims, agreeing that the "business of baseball" exemption applied to the Puerto Rico professional baseball league. However, the court vacated the District Court's dismissal of the Puerto Rico antitrust and fair competition claims, finding that the District Court had incorrectly applied the Supremacy Clause. The court also reversed the dismissal of the federal civil rights claim, concluding that the District Court had misapplied the doctrine of res judicata. Consequently, the court reversed the dismissal of the remaining Puerto Rico law claim, as a federal claim remained in the case. View "Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc." on Justia Law

East Gate-Logistics Park Chicago, LLC and NorthPoint Development, LLC (the East Gate parties) are involved in a dispute with CenterPoint Properties Trust and its affiliates (the CenterPoint parties) over development projects in the Joliet Intermodal Zone in Illinois. CenterPoint entered into a Memorandum of Understanding (MOU) with local authorities to build a toll bridge, while East Gate later secured an agreement allowing heavy trucks to bypass this toll bridge, which CenterPoint claims violates the MOU.The CenterPoint parties sued in Will County Court to enjoin the East Gate agreement, initially losing but later securing a preliminary injunction on remand from the Illinois Appellate Court. The state court has yet to rule on the merits. Subsequently, the East Gate parties filed a federal antitrust lawsuit, claiming the MOU unlawfully restricted competition. The CenterPoint parties argued the federal court lacked jurisdiction under the Rooker-Feldman doctrine, should abstain under the Colorado River doctrine, and that the Noerr-Pennington doctrine shielded them from antitrust liability.The United States District Court for the Northern District of Illinois rejected the Rooker-Feldman argument, dismissed the Noerr-Pennington motion without addressing the merits, but stayed the federal proceedings under Colorado River. The East Gate parties appealed the stay, while the CenterPoint parties cross-appealed the rejection of their motions.The United States Court of Appeals for the Seventh Circuit dismissed the appeal for lack of jurisdiction, determining that the stay did not effectively end the federal case and was merely a case management decision. The court also found no basis for immediate appeal of the interlocutory orders denying the motions to dismiss, as these could be reviewed after a final decision. View "East Gate-Logistics Park Chicago, LLC v. CenterPoint Properties Trust" on Justia Law

In November 2023, Media Matters for America, a nonprofit organization, published articles critical of X Corp. and its CEO, Elon Musk, alleging that advertisements from popular brands were placed next to harmful content on the X platform. This led to significant losses for X as advertisers withdrew. X sued Media Matters and its employees in the federal district court for the Eastern District of Texas, alleging interference with contract, business disparagement, and interference with prospective economic advantage. Media Matters moved to dismiss the complaint for lack of personal jurisdiction, improper venue, and failure to state a claim, but the district court denied the motion. Media Matters then sought to certify the personal jurisdiction question for immediate appeal, which was also denied.The district court denied Media Matters' subsequent motion to transfer venue to the Northern District of California, citing untimeliness and a pattern of gamesmanship. Media Matters then filed a petition for writ of mandamus with the United States Court of Appeals for the Fifth Circuit, seeking a venue transfer based on 28 U.S.C. §§ 1404 and 1406.The United States Court of Appeals for the Fifth Circuit reviewed the petition and found that the district court had not properly considered the eight public- and private-interest factors required for a venue transfer analysis. The appellate court granted Media Matters' petition in part, vacated the district court's order denying the transfer, and remanded the case for a proper venue analysis. The court also held Media Matters' interlocutory appeal in abeyance pending the resolution of the remand. View "In Re: Media Matters for America" on Justia Law

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

Anderson & Koch Ford, Inc., a Ford dealership in North Branch, Minnesota, operates under a Ford Sales and Service Agreement. In late 2022, Ford announced plans to establish a new dealership in Forest Lake, Minnesota, and to reassign half of Anderson & Koch’s designated sales area to the new dealership. Anderson & Koch filed a lawsuit in state court, alleging violations of the Minnesota Motor Vehicle Sale and Distribution Act (MVSDA), specifically sections 80E.13(k) and (p). Ford removed the case to federal court and moved to dismiss the claims.The United States District Court for the District of Minnesota partially granted Ford’s motion to dismiss, ruling that Anderson & Koch failed to state a claim under sections 80E.13(k) and (p) regarding the establishment of the new dealership. However, the court allowed Anderson & Koch to challenge the proposed change to its designated sales area under the same sections. Anderson & Koch then appealed the dismissal of its claims related to the new dealership.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Anderson & Koch could not challenge the establishment of the new dealership under sections 80E.13(k) or (p) of the MVSDA. The court held that the establishment of a new dealership did not modify the existing franchise agreement, as required by section 80E.13(k), nor did it arbitrarily change the dealer’s area of sales effectiveness under section 80E.13(p). The court also noted that Anderson & Koch had dismissed its claims regarding the change to its sales area, leaving only the challenge to the new dealership on appeal. View "Anderson & Koch Ford, Inc. v. Ford Motor Company" on Justia Law

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

Sysco Machinery Corporation, a Taiwanese company, accused DCS USA Corporation, a North Carolina company, of business torts related to their manufacturer-distributor relationship. Sysco alleged that after some of its employees left to form a competitor, Cymtek Solutions, Inc., DCS sold machines made by Cymtek using Sysco's confidential information. Sysco claimed these diverted contracts were worth millions of dollars.Sysco first filed suit in Taiwan, where it claims to have won a preliminary injunction against Cymtek. Sysco then filed a suit in the Eastern District of North Carolina, which it voluntarily dismissed, followed by a suit in the District of Massachusetts, which was dismissed. Finally, Sysco returned to the Eastern District of North Carolina, where it brought claims for trade secret misappropriation, copyright infringement, unfair and deceptive trade practices, and tortious interference with prospective economic advantage. The district court dismissed all claims under Rule 12(b)(6) for failure to state a claim and denied Sysco's post-judgment leave to amend its complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Sysco's trade secret misappropriation claim, finding that Sysco did not plausibly allege the existence of a valid trade secret or that DCS misappropriated it. The court also affirmed the dismissal of Sysco's other claims, noting that Sysco did not sufficiently develop its arguments for copyright infringement, unfair and deceptive trade practices, and tortious interference with prospective economic advantage. Finally, the court upheld the district court's denial of Sysco's motion to alter or amend the judgment and for leave to amend the complaint, citing Sysco's repeated failure to state a claim and the potential prejudice to DCS. View "Sysco Machinery Corp. v. DCS USA Corp." on Justia Law

Ian Elliot, Cindy Elliot, and their mother, Ada Elliot, were partners in StarFire, a limited partnership owning property in Gallatin County. Cindy managed StarFire and sought to remove Ian as a general partner. Ian was appointed Ada’s guardian, and Joyce Wuertz was appointed as Ada’s conservator. Ian sued Cindy for misappropriation of funds and sought to remove Wuertz as conservator, but his motions were denied. Ada’s will divided her estate equally between Ian and Cindy, but due to their strained relationship, a special administrator was appointed instead of Ian. Ian’s subsequent motions to disqualify the special administrator were also denied.The Thirteenth Judicial District Court, Yellowstone County, appointed Andrew Billstein as the special administrator of Ian’s estate. The Objectors (Jenny Jing, Alice Carpenter, and Mike Bolenbaugh) filed an untimely appeal against this appointment, which was declined. The Objectors also opposed the settlement agreements proposed by the Special Administrator, which aimed to resolve ongoing litigation involving Ian’s estate. The District Court approved the settlements, finding them reasonable under the Pallister factors, and denied the Objectors’ motion for relief under M. R. Civ. P. 59 and 60.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decisions. The court held that the District Court had subject matter jurisdiction to approve the settlement agreements and did not abuse its discretion in doing so. The court found that the settlements were reasonable, considering the strength of the cases, the risk and expense of further litigation, and the views of experienced counsel. The court also upheld the District Court’s denial of the Objectors’ post-judgment relief motions. View "In re Estate of Elliot" on Justia Law