Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

In a contract dispute related to the funding of the development of the Fountainebleau Resort in Las Vegas (the Project), Term Lenders appealed the district court's grant of summary judgment in favor of the Bank. The court concluded that under the Disbursement Agreement the Bank was permitted to rely on the Borrowers' certifications that the conditions precedent were satisfied unless it had actual knowledge to the contrary. The court also concluded that there remained genuine issues of material fact about whether the Bank had such knowledge and whether its actions amounted to gross negligence. The court affirmed the district court's denial of the Term Lenders' Motion for Partial Summary Judgment and the district court's interpretation of the Bank's obligations under the Disbursement Agreement. The court reversed, however, the district court's grant of summary judgment in favor of the Bank and the court remanded the case for further proceedings. View "Avenue CLO Fund, Ltd., et al. v. Bank of America, NA" on Justia Law

This case involved disputes over licensing agreements for, inter alia, the RS 3400 blood irradiation device. At issue was whether the Federal Circuit has exclusive jurisdiction to hear an appeal of a breach of contract claim that would require the resolution of a claim of patent infringement for the complainant to succeed. The court concluded that it did not have appellate jurisdiction and resolved dispositive issues in favor of Rad Source, leaving a single dispositive issue for certification: When a licensee enters into a contract to transfer all of its interests in a license agreement for an entire term of a license agreement, save one day, but remains liable to the licensor under the license agreement, is the contract an assignment of the license agreement, or is the contract a sublicense? View "MDS (Canada) Inc., et al. v. Rad Source Technologies, Inc." on Justia Law

The bankruptcy trustee of Northlake, a Georgia corporation, filed suit against defendant, a shareholder of Northlake, alleging that a 2006 Transfer was fraudulent. The facts raised in the complaint and its exhibits, taken as true, were sufficient to conclude that Northlake's benefits under the Shareholders Agreement were reasonably equivalent exchange for the 2006 Transfer. Because the complaint contained no allegations indicating why these benefits did not constitute a reasonably equivalent exchange for the 2006 Transfer, the court had no ground to conclude that they did not. Accordingly, the court affirmed the judgment of the district court. View "Crumpton v. Stephen" on Justia Law

Merle Wood, a yacht-broker, appealed the district court's grant of summary judgment in favor of Trinity, a manufacturer and seller of yachts. Merle Wood sued Trinity for, among other things, quantum meruit and unjust enrichment. Merle Wood alleged that Trinity refused to pay for the fair, reasonable value of the benefit it provided in brokering a deal that led to Trinity selling two multi-million dollar yachts. The court held that Merle Wood's quantum meruit and unjust enrichment causes of action were time-barred under Fla. Stat. 95.11. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Trinity. View "Merle Wood and Assoc., Inc v. Trinity Yachts, LLC" on Justia Law

Plaintiff, on behalf of herself and the Estate, challenged the district court's grant of summary judgment to Zenith on the Estate's breach of the insurance contract claim. After review and oral argument, the court certified questions to the Florida Supreme Court: (1) Does the estate have standing to bring its breach of contract claim against Zenith under the employer liability policy? (2) If so, does the provision in the employer liability policy which excludes from coverage "any obligation imposed by workers' compensation . . . law" operate to exclude coverage of the estate's claim against Zenith for the tort judgment? (3) If the estate's claim was not barred by the workers' compensation exclusion, does the release in the workers' compensation settlement agreement otherwise prohibit the estate's collection of the tort judgment? View "Morales v. Zenith Ins. Co." on Justia Law

Travelers moved to dismiss Postel's appeal of the district court's stay of Postel's lawsuit seeking payment from Travelers on a surety bond for work that it performed as a subcontractor. Postel brought its suit pursuant to the Miller Act, 40 U.S.C. 3131 et seq. Travelers argued that Postel's appeal, which was not filed until fifty-five days after the district court's order, was untimely. Because Postel did not argue that the United States had any involvement in this case, but instead relied solely on the statutory requirement that it bring its Miller Act claim in the name of the United States, the court concluded that it was required to file its notice of appeal within thirty days under Rule 4(a)(1)(A). Accordingly, the court granted Travelers' motion to dismiss the appeal for lack of jurisdiction. View "United States for the use and benefit of Postel Erection Group, L.L.C., et al v. Travelers Casualty and Surety, et al" on Justia Law

This case stemmed from the fallout from the failure of the Fountainebleau development in Las Vegas, Nevada and involved the contract dispute between the Term Lenders, the Revolving Lenders, and the Borrowers. The district court dismissed the Term Lenders' claims against the Revolving Lenders, finding that the Term Lenders lacked standing to sue. The district court also denied the Borrowers' motion for summary judgment against the Revolving Lenders, rejecting the Borrowers' argument that the Revolving Lenders had breached the contract as a matter of law and alternatively finding there were material issues of fact about whether the Revolving Lenders breached the contract. The court held that the Term Lenders lacked standing to enforce section 2.1(c) of the Credit Agreement promise and affirmed the district court's dismissal of the breach of contract claims. The court could not conclude as a matter of law that the Revolving Lenders broke their promise to fund the Borrowers under section 2 of the Credit Agreement and affirmed the district court's denial of the Borrowers' request for turnover of the loan proceeds and specific performance. View "Avenue CLO Fund, Ltd., et al v. Bank of America, NA, et al" on Justia Law

Allianz appealed the district court's grant of judgment in favor of plaintiff on his claim that Allianz miscalculated the monthly benefit to which he was entitled under a long-term disability insurance policy. Allianz contended that the district court improperly interpreted the offset provision of the policy. The court concluded that the policy's offset provision was not afflicted with ambiguity and the district court should not have resorted to canons of construction to determine the unwritten intent of the provision. Accordingly, the court reversed and remanded for entry of judgment in favor of Allianz. View "Duckworth v. Allianz Life Ins. Co., et al" on Justia Law

Buyers sued Bahamas Sales, and others associated with Bahamas Sales, alleging that they engaged in appraisal fraud. Buyers purchased undeveloped lots in a planned resort in the Bahamas where the purchase contracts contained a provision that required all disputes to be litigated in the Bahamas. The district court dismissed for improper venue. The court held that the district court erred when it determined that Buyers' claims fell within the scope of the lot purchase contracts' forum-selection clauses; the district court erred in applying equitable estoppel to allow the Mortgage Entities and the Credit Suisse Entities (nonsignatories to the lot purchase contracts) to invoke the lot purchase contracts' forum-selection clauses; and reversed the district court's judgment granting the motions to dismiss for improper venue and remanded for further proceedings. View "Bailey, et al v. ERG Enterprises, LP, et al" on Justia Law

SJH sued HMA for breach of contract and, in the alternative, under the doctrine of promissory estoppel, after HMA reneged on its "promise" to purchase the assets of SJH. By filing the Premerger Notifications, the parties represented the following as true: (1) the Asset Sale Agreement would not become a binding, enforceable contract until signed by the parties; (2) the Letter of Intent superseded any agreements - whether written or oral - that could have existed between the parties regarding HMA's acquisition of the hospital assets; and (3) the parties had a good faith intention to complete the transaction and were not using the notification process to vet a purely hypothetical transaction with the agencies. To this end, the parties were obligated to attend the hearing the Georgia Attorney General had scheduled and to cooperate with each other in presenting the case of HMA's acquisition. In light of these findings, the court found no error in the district court's decision to grant HMA summary judgment on the breach of contract claim (Count 1). The court also held that SJH's promissory estoppel claim (Count 4) failed because the Letter of Intent "clearly reflected the parties' intentions not to be bound until a definitive and binding [Asset Sale Agreement] was finalized and executed." View "St. Joseph Hospital, Augusta, et al v. Health Mgmt. Assoc., Inc." on Justia Law