Justia Civil Procedure Opinion Summaries

Chesapeake Exploration, LLC (Chesapeake) and Morton Production Company, LLC (Morton) entered into a joint operating agreement for oil and gas development in Converse County, Wyoming. Morton sued Chesapeake for breach of contract, violation of the Wyoming Royalty Payment Act (WRPA), and conversion after Chesapeake adjusted Morton’s ownership interest and withheld production proceeds. Chesapeake counterclaimed for breach of contract, unjust enrichment, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment in favor of Morton.Chesapeake appealed, challenging the district court’s summary judgment on Morton’s breach of contract claim, the supplemental decision on Chesapeake’s counterclaims and affirmative defenses, and the determination that Chesapeake violated the WRPA. The Wyoming Supreme Court reviewed the case.The Wyoming Supreme Court affirmed the district court’s decision. It held that Chesapeake breached the contract by adjusting Morton’s ownership interest and billing for costs beyond the twenty-four-month limitation period specified in the 1985 COPAS Form, which was incorporated into the joint operating agreement. The court found the language in the COPAS Form unambiguous and declined to consider extrinsic evidence. The court also upheld the district court’s use of Rule 60(a) to correct a clerical error in its original order and found that Chesapeake’s counterclaims were properly dismissed as they were rendered moot by the summary judgment on Morton’s claims. Additionally, the court ruled that Chesapeake violated the WRPA by withholding production proceeds without placing the disputed funds in escrow, as required by the statute. View "Chesapeake Exploration, LLC, v. Morton Production Company, LLC" on Justia Law

CEZ Prior, LLC ("CEZ") entered into a purchase agreement with 755 N Prior Ave., LLC ("Prior") to buy a property for $26 million. The agreement required Prior to cooperate in obtaining tenant estoppel certificates. Errors in square footage measurements led to rent discrepancies, prompting an amendment to reduce the purchase price to $15.1 million and the cash required at closing to $3.8 million. CEZ later requested to delay closing due to financial issues, but Prior did not agree. Prior sent estoppel certificates that did not address rate increases, and CEZ proposed edits that Prior rejected. CEZ demanded satisfactory certificates on the closing date, but Prior terminated the agreement, alleging CEZ failed to tender cash.CEZ sued Prior for breach of contract in Minnesota state court and sought to enjoin the termination. Prior removed the case to federal court and counterclaimed for breach of contract. The district court stayed the matter and later denied CEZ's motion for a preliminary injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court's denial of the preliminary injunction. The court found that CEZ was unlikely to succeed on the merits of its breach of contract claim, as Prior had reasonably cooperated in obtaining the estoppel certificates. The balance of harms favored Prior, given CEZ's insufficient evidence of its ability to pay. The public interest did not favor CEZ due to its low probability of success on the merits.The court also addressed CEZ's argument under Minnesota law, finding that the district court's stay order was not an injunction and did not extend statutory deadlines. Consequently, CEZ was not entitled to additional time to close under Minnesota statutes. The Eighth Circuit affirmed the district court's judgment. View "CEZ Prior, LLC v. 755 N Prior Ave. LLC" on Justia Law

Automotive Finance Corporation (AFC) extended a loan to Monmars Automotive Group LLC, which was guaranteed by Meng Liu, her then-husband Ning Ao, and Liu’s friend Xiaoqiao Yang. After Monmars defaulted, AFC sued to recover the debt. Liu, representing herself, filed unsworn letters claiming she did not sign the loan agreement. The trial court granted summary judgment for AFC. Ao later admitted in an unsworn letter to forging Liu’s and Yang’s signatures, but Liu did not file a motion to correct error or appeal properly.The Marion Superior Court set aside the judgment based on fraud under Trial Rule 60(B)(3) after Liu, now represented by counsel, presented Ao’s testimony about the forgery. AFC appealed, and the Indiana Court of Appeals issued conflicting opinions in related cases. In Liu’s case, the court affirmed the trial court’s decision, but in Yang’s case, it reversed.The Indiana Supreme Court reviewed the case and held that the trial court abused its discretion in granting relief under Trial Rule 60(B)(3). The court found that Liu could have raised the fraud issue in a timely motion to correct error or on appeal. Additionally, there was no evidence that the alleged fraud prejudiced Liu’s ability to present her case. The court emphasized the importance of finality in judgments and the need for litigants, including those representing themselves, to comply with procedural requirements.The Indiana Supreme Court reversed the trial court’s decision and remanded the case for reinstatement of summary judgment in favor of AFC. View "Automotive Finance Corporation v. Liu" on Justia Law

Christine Berger and Brian Repnow were in a decade-long relationship but never married. During their relationship, they accumulated various properties and businesses. In August 2021, Berger filed a lawsuit seeking partition, conversion, promissory estoppel, and unjust enrichment, requesting an equitable division of their accumulated real and personal property or monetary damages. Repnow claimed sole ownership of the properties and requested denial of Berger's claims.The District Court of Mercer, South Central Judicial District, held a two-day bench trial in October 2023. The court granted Berger's partition claim for the Expansion Drive property, awarding her sole ownership, and determined that the other properties and vehicles were solely owned by Repnow. The court also granted Berger's unjust enrichment claim, awarding her $64,000 for her contributions to Repnow's properties, and denied the claims of conversion and promissory estoppel. The court awarded the Dream Girls Boutique business to Repnow and Powerhouse Nutrition to Berger.The North Dakota Supreme Court reviewed the case. The court affirmed the district court's finding that the parties intended to share ownership of the Expansion Drive property and the award of Powerhouse Nutrition to Berger. However, it reversed the decision to award 100% of the Expansion Drive property to Berger, stating that the district court should have considered the parties' respective ownership interests and made an equitable division. The court also found that the district court failed to complete the unjust enrichment analysis and adequately explain the $64,000 award.The North Dakota Supreme Court remanded the case for the district court to determine the parties' respective ownership interests in the Expansion Drive property and make an award consistent with those interests. The court also instructed the district court to complete the unjust enrichment analysis and provide a clear explanation for the $64,000 award if necessary. View "Berger v. Repnow" on Justia Law

Monsanto Company, Pharmacia, LLC, and Solutia, Inc. (collectively, "Monsanto") filed a lawsuit in St. Louis County Circuit Court in Missouri against Magnetek, Inc., General Electric Co. ("GE"), Paramount Global, KYOCERA AVX Components Corporation, Cornell Dubilier Electronics, Inc., and The Gillette Company LLC (collectively, "Defendants"). Monsanto alleged that it continues to incur substantial costs to defend against PCB lawsuits that should be borne by Defendants and sought to enforce written agreements obligating Defendants to defend, indemnify, and hold Monsanto harmless in all currently pending and future PCB lawsuits.GE removed the action to federal court, asserting jurisdiction under the federal officer removal statute, 28 U.S.C. § 1442(a)(1). The United States District Court for the Eastern District of Missouri granted Monsanto’s motion to remand, finding that GE's removal was untimely. GE appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the parties had waived Missouri Supreme Court Rule 54.13(c)’s personal service provision and expressly agreed that January 31, 2023, was the effective date for service of process. The court determined that the 30-day removal period began on the agreed effective date of service, not when GE signed the acknowledgment and waiver of service of process or when Monsanto filed the document. Consequently, GE's notice of removal was filed within the 30-day period, making the removal timely.The Eighth Circuit vacated the district court’s order of remand and remanded the case for further proceedings consistent with its opinion. The court declined to address whether GE satisfies the government contractor requirement of 28 U.S.C. § 1442(a)(1), as this issue was not addressed by the district court. View "Monsanto Company v. General Electric Co." on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Appellants CKHS, Inc. and The Foundation for Delaware County sought a preliminary injunction to prevent Appellees Prospect Medical Holdings, Inc. and Prospect Crozer, LLC from converting Delaware County Memorial Hospital from an emergency and acute care facility to a behavioral health hospital. The asset purchase agreement (APA) between the parties included clauses requiring Prospect to maintain key service lines, including emergency medicine, for five years and to consult with a local advisory board before making significant changes after that period. Additionally, the APA stipulated that any breach would cause irreparable damage.The Delaware County Court of Common Pleas granted the preliminary injunction, finding that Appellants demonstrated the necessary prerequisites, including irreparable harm. The court relied on the APA's irreparable harm clause and expert testimony from Melissa Lyon, who testified that removing healthcare access points from a community almost always negatively impacts health outcomes, particularly for socioeconomically disadvantaged and elderly populations.The Commonwealth Court reversed the trial court's order, concluding that the trial court abused its discretion by finding irreparable harm based on speculative and hypothetical evidence. The Commonwealth Court held that the APA's irreparable harm clause alone was insufficient and required concrete evidence of harm, which it found lacking in Lyon's testimony.The Supreme Court of Pennsylvania reviewed the case and determined that the Commonwealth Court misapplied the appellate standard of review, which requires a highly deferential approach to the trial court's decision. The Supreme Court found that the trial court had apparently reasonable grounds to issue the preliminary injunction based on Lyon's testimony and the APA's irreparable harm clause. Consequently, the Supreme Court reversed the Commonwealth Court's order and remanded the case for further proceedings to address the remaining factors for preliminary injunctive relief. View "CKHS, Inc. v. Prospect Med Hldgs, Inc." on Justia Law

A borrower misrepresented his authority to act on behalf of two corporations he intended to acquire, providing false documents to a lender. Despite having documents contradicting the borrower's claims, the lender proceeded with a $7 million loan, including a confession-of-judgment affidavit naming the corporations as additional borrowers. When the borrower defaulted, the lender sought a confessed judgment against all borrowers, including the corporations, whose true officers were unaware of the transaction until served with notice of the judgment.The Superior Court of Delaware conducted a hearing and entered judgment in favor of the lender, finding that the borrower had apparent authority to bind the corporations. The court focused on the borrower's conduct and representations, concluding that they created the impression of authority sufficient to warrant the entry of a confessed judgment against the corporations.The Supreme Court of Delaware reviewed the case and found that the Superior Court's formulation of the test for apparent authority was flawed. The Supreme Court emphasized that apparent authority must be based on the principal's manifestations, not solely on the agent's conduct. The evidence did not support a finding that the corporations acted in a way that created a reasonable belief in the lender that the borrower was authorized to bind them. Consequently, the Supreme Court reversed and vacated the Superior Court's judgment, concluding that the borrower lacked apparent authority and that the corporations did not effectively waive their due process rights. View "Caribbean Sun Airlines Inc. v. Halevi Enterprises LLC" on Justia Law

In this case, G.P.P., Inc. (GIS) sued Guardian Protection Products, Inc. (Guardian) and RPM Wood Finishes Group, Inc. (RPM) for breach of contract and other claims related to nine warehousing distributor agreements (WDAs). GIS alleged that Guardian wrongfully terminated three WDAs and threatened to terminate the remaining six. GIS sought damages and other relief, while Guardian countersued for declaratory relief and breach of contract.The United States District Court for the Eastern District of California conducted two trials. In the first trial, the jury rejected all claims and counterclaims. GIS appealed, and the Ninth Circuit reversed the district court's summary judgment on certain claims, leading to a second trial. In the second trial, the jury awarded GIS $6 million in damages. GIS then sought attorney’s fees from Guardian, while Guardian and RPM sought fees from GIS.The United States Court of Appeals for the Ninth Circuit reviewed the district court's award of over $4 million in attorney’s fees to GIS. The Ninth Circuit found that the district court correctly deemed GIS the prevailing party against Guardian, as GIS successfully defended against Guardian’s counterclaims and won significant damages. However, the Ninth Circuit held that the district court erred in its analysis of RPM’s entitlement to fees. The district court had deemed certain claims voluntarily dismissed, but the Ninth Circuit concluded that GIS did not provide adequate notice of its intent to abandon those claims. Therefore, the Ninth Circuit reversed the district court’s decision regarding the abandoned claims and remanded for further determination of fees due to RPM.The Ninth Circuit affirmed the district court’s methodology and equitable considerations in deeming GIS the prevailing party against Guardian but reversed and remanded the decision regarding RPM’s entitlement to fees. View "GPP, INC. V. GUARDIAN PROTECTION PRODUCTS, INC." on Justia Law

Jason Terrell, M.D., provided consulting services and served on the board of directors of Kiromic Biopharma, Inc. between December 2014 and May 2021. During this period, Kiromic awarded Terrell stock options through three separate agreements. The first agreement granted Terrell an option to purchase 500,000 shares at $0.50 per share for consulting services. The second agreement, made when Terrell joined the board, granted him an option to purchase 500,004 shares at $0.17 per share. The third agreement, which included a waiver clause, granted him an option to purchase 500,004 shares at $0.19 per share. After Terrell resigned from the board in September 2019, Kiromic refused to honor the options from the first two agreements, claiming that Terrell waived his rights to those options in the third agreement.The Court of Chancery dismissed Terrell’s complaint seeking specific performance of the first two option grants, finding that the waiver clause in the third agreement unambiguously extinguished Terrell’s rights to the previous option awards. The court held that the language in the waiver clause, which stated that Terrell had no other rights to any other options or securities of the company, was clear and that the carveout for "securities issued" did not include unexercised options.The Supreme Court of the State of Delaware reviewed the case and found that the waiver language was susceptible to more than one reasonable interpretation. The court noted that the term "securities" could reasonably include options and that the parties' use of the word "issued" did not exclusively refer to shares. Therefore, the court concluded that the waiver clause was ambiguous and that the case should not have been dismissed at the pleadings stage. The Supreme Court reversed the Court of Chancery’s dismissal of the complaint and remanded the case for further proceedings. View "Terrell v. Kiromic Biopharma, Inc." on Justia Law