Justia Landlord - Tenant Opinion Summaries
DM Trans, LLC v. Scott
Arrive and Tech, compete to help customers coordinate shipments. Six employees at Arrive departed for Tech despite restrictive covenants. Arrive sued the six individuals and Tech for injunctive relief under the Defend Trade Secrets Act, 18 U.S.C. 1836(b)(3), claiming irreparable harm because the individuals had breached their restrictive covenants and misappropriated trade secrets.The Seventh Circuit affirmed the denial of a preliminary injunction. Arrive has an adequate remedy at law for each of its claimed injuries, and faces no irreparable harm. Even if its argument were not forfeited, lost opportunities cannot support a showing of irreparable harm under these circumstances. The type of harm Arrive alleges would ultimately translate into lost profits, albeit indirectly, as in the end there is no economic value to opportunities that are not converted to sales. Given the balance of harms, the district court was within its discretion to deny injunctive relief. The court noted that the expiration of the time period of a former employee’s restrictive covenants does not render moot an employer’s request for an injunction to prevent the former employee from violating those restrictive covenants. A court could still grant Arrive effectual relief in the form of an injunction, even though certain individual defendants no longer work for Traffic Tech. View "DM Trans, LLC v. Scott" on Justia Law
JJD-HOV Elk Grove, LLC v. Jo-Ann Stores
The co-tenancy provision in the parties’ lease required a shopping center to have either: (1) three anchor tenants; or (2) 60 percent of the space leased, and, if it did not, Tenant-respondent JoAnn Stores, LLC was permitted to pay “Substitute Rent.” In 2018, Jo-Ann informed JJD it intended to start paying Substitute Rent effective July 1, 2018, because the co-tenancy provision was not met after two anchor tenants closed. Landlord-appellant JJD-HOV Elk Grove, LLC (JJD) responded that the co-tenancy provision was an unenforceable penalty under the holding in Grand Prospect Partners, L.P. v. Ross Dress for Less, Inc., 232 Cal.App.4th 1332 (2015). Jo-Ann contended Grand Prospect was distinguishable and the co-tenancy provision was enforceable. JJD and Jo-Ann filed competing complaints for declaratory relief and cross-motions for summary judgment. The trial court found the co-tenancy provision was enforceable, and thus granted Jo- Ann’s motion, denied JJD’s, and entered judgment accordingly. JJD appealed. The Court of Appeal declined to follow the rule announced in Grand Prospect here, and instead held that this case was governed by the general rule that courts enforce contracts as written. The Court therefore agreed with the trial court’s conclusion that the co-tenancy provision at issue in this case was enforceable, and affirmed the judgment. View "JJD-HOV Elk Grove, LLC v. Jo-Ann Stores" on Justia Law
EDC Investment, LLC v. UTGR, Inc.
The Supreme Court affirmed the order of the superior court granting a motion to dismiss filed by Defendant and dismissed this complaint alleging, among other things, breach of fiduciary duty and breach of contract, holding that the complaint was properly dismissed.In 2000, Plaintiff and Defendant entered into a lease agreement whereby Plaintiff rented space from Defendant. In 2011, the parties entered into a termination of lease and release agreement providing Plaintiff with a buyout. Plaintiff later brought this action. Defendant want moved to dismiss the complaint, arguing that Plaintiff released all claims against Defendant in a release. The hearing justice granted the motion. The Supreme Court affirmed, holding that the hearing justice did not err in dismissing Plaintiff's claims of breach of fiduciary duty and breaches of contract and the covenant of good faith and fair dealing. View "EDC Investment, LLC v. UTGR, Inc." on Justia Law
55 Oak Street LLC v. RDR Enterprises, Inc.
The Supreme Judicial Court vacated the judgment of the superior court affirming the judgment of the district court that denied Landlord's forcible entry and detainer (FED) action to oust Tenant from possession of Landlord's property, holding that Tenant's breach of the terms of its lease entitled Landlord to issuance of a writ of possession.The district court concluded that Landlord was not entitled to possession of the subject property because Tenant's failure to pay its rent was at least in part excused by the force majeure clause in the parties' lease. The Supreme Judicial Court vacated the judgment, holding that Tenant's breach of the terms of its lease entitled Landlord to issuance of a writ of possession. View "55 Oak Street LLC v. RDR Enterprises, Inc." on Justia Law
Caswell, et al. v. AHTNA, Inc.
A miner signed a 20-year lease with a corporate landowner for an easement allowing him access to his limestone-mining operation. The lease included an option to extend it for up to three additional 10-year terms as long as the miner was not in default and gave prior written notice of his intent to extend. At the close of year 19, the miner sent a check prepaying the final calendar year, plus the six weeks following the lease’s expiration date. And after the expiration date the miner sent another check prepaying the next year (year 21) without ever providing the express notice of intent to extend required by the lease. The corporation accepted both of the rent checks. Five months later the corporation sued the miner and his company, contending that he was in breach and the lease had expired. The corporation later amended its complaint to add a claim for forcible entry and detainer seeking to recover possession of the premises by court order, and shortly afterward served the miner with a notice to quit. The court held a hearing nearly 11 months later and granted the forcible-entry claim. Appealing, the miner contended the parties’ dispute was too complex to be resolved through forcible entry and detainer proceedings with limited opportunities for discovery; that the forcible entry and detainer proceeding was unlawful because at the time the claim was asserted the corporation had not yet served the notice to quit; and that the miner’s company was improperly named as a defendant and included in the forcible entry and detainer judgment. Finding no reversible error, the Alaska Supreme Court affirmed the superior court's judgment. View "Caswell, et al. v. AHTNA, Inc." on Justia Law
Trenton Indian Housing Authority v. Poitra, et al.
Lisa Poitra appealed an order of eviction, arguing the district court lacked jurisdiction to enter the eviction order because the Trenton Indian Housing Authority (“TIHA”) constituted a dependent Indian community, and a contract provision required the eviction to be handled by the Turtle Mountain Band of Chippewa Indians Tribal Court. The North Dakota Supreme Court concluded the record supported the district court’s finding that TIHA was not a dependent Indian community, the court’s determination that it had subject matter jurisdiction, and the finding TIHA did not have a contractual obligation to bring the eviction action in the tribal court. View "Trenton Indian Housing Authority v. Poitra, et al." on Justia Law
Horizon Ventures of W. Va., Inc. v. American Bituminous Power Partners, L.P.
The Supreme Court reversed the business court's orders in this rent dispute, holding that the business court erred in granting summary judgment to either party.American Bituminous Power Partners, LP (AMBIT) and Horizon Ventures of West Virginia, Inc. created a contractual relationship with a lease agreement. The current rent dispute involved the relationship between the lease, a 1996 settlement agreement, and a 2017 order of the business court. Without resolving the relationship between those documents the business court granted summary judgment to AMBIT on Horizon's claims and summary judgment to Horizon on AMBIT's claims. The Supreme Court reversed, holding that summary judgment was improper because the various agreements were ambiguous and the parties' intent was not clear. View "Horizon Ventures of W. Va., Inc. v. American Bituminous Power Partners, L.P." on Justia Law
Association of Village Council Presidents Regional Housing Authority v. Mael, et al.
A boiler exploded in a home owned by a nonprofit regional housing authority, severely injuring a man who lived there. He sued the housing authority in both contract and tort, claiming that his lease-purchase contract included a promise that the authority would inspect the boiler, which it failed to do with reasonable care. After the man dismissed his contract claim, the housing authority asked the court to decide as a matter of law that a breach of a contractual promise could not give rise to a tort claim. But the superior court allowed the man to proceed to trial on his tort claim, and the jury awarded over $3 million in damages, including over $1.5 million in noneconomic damages and separate awards to several of his family members for negligent infliction of emotional distress. The court reduced the man’s noneconomic damages award to $1 million because of a statutory damages cap, but it excluded the family members’ awards from the amount subject to the cap. The housing authority appealed, maintaining it should have been granted a judgment notwithstanding the verdict because the contract did not create a continuing legal duty to inspect the boiler with reasonable care. It also argued it should have been granted a new trial because it had established that the boiler explosion was caused by a product defect rather than negligent inspection. Finally, the authority argued the family members’ damages for negligent infliction of emotional distress should have been included in the amount subject to the statutory damages cap. The man cross-appealed, arguing that the damages cap violated due process because it failed to account for inflation or the severe nature of his physical injuries. After review, the Alaska Supreme Court found no reversible error and affirmed the superior court's judgment on all issues. View "Association of Village Council Presidents Regional Housing Authority v. Mael, et al." on Justia Law
McKeeman v. Duchaine
The Supreme Judicial Court vacated the judgment of the district court that characterized the court's prior order on Appellants' motion for a preliminary injunction as a ruling on the merits and entering a final judgment without holding a hearing, holding that the court's order violated Me. R. Civ. P. 65(b)(2).Appellants filed this complaint alleging violations of the statutory warranty of habitability and an illegal eviction and seeking injunctive and declaratory relief. After a hearing, the court entered an order granting in part and denying in part Appellants' request for a preliminary injunction. Thereafter, Appellants filed a request for default judgment. The court denied the request and then entered the order as a final judgment. The Supreme Judicial Court vacated the judgment below, holding that the order, which treated the hearing on the motion for a preliminary injunction as a consolidated hearing on the motion and on the merits, violated Me. R. Civ. P. 65(b)(2) and offended due process. View "McKeeman v. Duchaine" on Justia Law
Natal v. GMPM Company & al.
Defendants GMPM Company and 479 Maple Street, LLC, appealed a circuit court order granting the petition for wrongful eviction filed by plaintiff Melissa Natal. On appeal, defendants argued the circuit court erred by determining that its property was not a “shared facility” as defined by RSA 540-B:1 (2021). Specifically, defendants argued RSA 540-B:1 did not require that an owner occupy the premises, but, rather, only that an owner have access to the common areas for the purposes of cleaning, maintaining, and monitoring the premises. The New Hampshire Supreme Court concluded that, for property to qualify as a shared facility under RSA 540-B:1, the owner had to reside at the premises with the occupants. Accordingly, judgment was affirmed. View "Natal v. GMPM Company & al." on Justia Law