Justia Antitrust & Trade Regulation Opinion Summaries

This case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court. View "Eller, et al. v. NFL Players Assoc., et al." on Justia Law

This interlocutory appeal arose from the district court's order certifying a class in Plaintiff's class action against Defendant, Allstate Insurance Company. Plaintiff's class action claim arose out of the Supreme Court's remand of his initial non-class third-party claim against Allstate in Jacobsen I. In Jacobsen I, Plaintiff filed a complaint against Allstate for, among other causes of action, violations of the Montana Unfair Trade Practices Act. Plaintiff sought both compensatory and punitive damages. The Supreme Court ultimately remanded the case for a new trial. On remand, Plaintiff filed a motion for class certification, proposing a class definition encompassing all unrepresented individuals who had either third- or first-party claims against Allstate and whose claims were adjusted by Allstate using its Claim Core Process Redesign program. The district court certified the class. The Supreme Court affirmed the class certification but modified the certified class on remand, holding that the district court did not abuse its discretion by certifying the Mont. R. Civ. P. 23(a)(2) class action but that the certification of class-wide punitive damages was inappropriate in the context of a Rule 23(b)(2) class. Remanded. View "Jacobsen v. Allstate Ins. Co." on Justia Law

This case arose from disputes between the Department of Information Technology and Defendant, a computer equipment supplier, over two contracts between the parties. The Department filed this action against Defendant, alleging breach of contract and fraud claims. Defendant filed an amended counterclaim, alleging takings and due process violations. The Department moved to dismiss the takings and due process claims based on the State's sovereign immunity. The trial court determined that the Department had waived the State's sovereign immunity regarding Defendant's counterclaims by bringing this cause of action against Defendant. After a jury trial, the trial court awarded Defendant damages on its procedural due process counterclaim. The Supreme Court (1) reversed the judgment of the trial court in favor of Defendant on the procedural due process counterclaim, holding that the Department did not waive the state's sovereign immunity by initiating the present litigation, and therefore, the trial court lacked subject matter jurisdiction over Defendant's counterclaims; and (2) affirmed in all other respects. View "Chief Info. Officer v. Computers Plus Ctr., Inc." on Justia Law

Leonard Landa was the sole managing member of a Montana limited liability corporation. Landa carried commercial general liability insurance through Assurance. After a former employee of Landa's filed a complaint alleging that Landa had committed various torts by inducing him to work for Landa under allegedly false pretenses, Landa tendered defense of the former employee's claim to Assurance. Assurance refused to defend Landa, stating that the complaint's allegations were not covered under Landa's policy. Landa filed a complaint seeking declaratory relief establishing that Assurance had a duty to defend and indemnify Landa and alleging violations of Montana's Unfair Trade Practices Act (UTPA), negligence, and other causes of action. The district court granted summary judgment for Assurance, finding that the complaint's allegations were not covered under Landa's policy and that Assurance was not liable under the UTPA because the denial of coverage was grounded on a legal conclusion. The Supreme Court affirmed, holding that Assurance correctly declined to provide a defense where the former employee's complaint did not allege an "occurrence" and, as a result, did not trigger a duty to defend under the policy. View "Landa v. Assurance Co. of Am." on Justia Law

Prime Motor Cars sold Seacoast RV, Inc. a car. The car had modifications that voided the manufacturer's warranty and caused mechanical problems that may not have been apparent when the car was sold because the "check engine" light was covered with opaque tape. Seacoast filed a complaint against Prime, alleging breach of contract, breach of warranty, fraud, violation of the Maine Unfair Trade Practices Act (UTPA), and punitive damages. The district court granted Prime's motion for judgment as a matter of law on the UTPA and punitive damages claims. The court then concluded that Prime's conduct constituted breach of contract and breach of warranty, but found against Seacoast on the fraud claim. The court rescinded the contract and ordered Prime to refund Seacoast and Seacoast to return the vehicle to Prime. The Supreme Court affirmed, holding that the district court did not err in its judgment.View "Seacoast RV, Inc. v. Sawdran, LLC" on Justia Law

The Leonards entered into contracts with Centennial for the sale of a log home kit and construction of a custom log home. The Leonards later released Centennial from any claims for damages for defective construction or warranty arising out of the home's construction. Greg and Elvira Johnston held a thirty-six percent interest in the property at the time the release was signed. Eventually, all interest in the property was transferred to the Elvira Johnston Trust. A few years later, because of a number of construction defects affecting the structural integrity of the house, the Johnstons decided to demolish the house. The Johnstons sued Centennnial for negligent construction, breach of statutory and implied warranties, and other causes of action. The district court granted summary judgment for Centennial, finding that the Johnstons' claims were time-barred and were waived by the Leonards' release. The Supreme Court (1) reversed the court's ruling that the Johnstons' claims were time-barred and directed that the decision on remand apply only to the interest owned by the Johnstons at the time the release was executed; and (2) affirmed the district court's conclusion that the release was binding on the Leonards' sixty-four percent interest, later transferred to the Trust. View "Johnston v. Centennial Log Homes & Furnishings, Inc." on Justia Law

Plaintiff Creative Playthings Ltd., a Massachusetts corporation, entered into a franchising agreement with Defendant under which Defendant agreed to operate a Creative Playthings franchise store in Florida. Plaintiff later terminated its agreement with Defendant and commenced this action against Defendant in the U.S. district court for breach of contract and associated claims. Defendant filed several counterclaims against Creative. Creative moved for summary judgment on Defendant's counterclaims, asserting they were time barred under the limitations provision in the franchise agreement. The federal district court judge declined to decide Creative's motion and instead certified the question of whether contractually shortened statutes of limitations are generally enforceable under Massachusetts law. The Supreme Court answered by holding that, in a franchise agreement governed by Massachusetts law, a limitations period in the contract shortening the time within which claims must be brought is valid and enforceable under Massachusetts law if the claim arises under the contract and the agreed-upon limitations period is subject to negotiation by the parties, is not otherwise limited by controlling statute, is reasonable, is not a statute of repose, and is not contrary to public policy.View "Creative Playthings Franchising Corp. v. Reiser" on Justia Law

Appellee initiated this putative class-action lawsuit against DIRECTV, seeking damages for herself individually and on behalf of other former DIRECTV subscribers who paid an early cancellation fee to DIRECTV after they terminated DIRECTV's service. Appellee alleged that DIRECTV's enforcement and collection of its early cancellation fee was deceptive and unconscionable in violation of the Arkansas Deceptive Trade Practices Act. Appellee moved to certify the litigation as a class action. DIRECTV moved to compel Appellee to arbitration in accordance with the arbitration provision in the customer agreement that DIRECTV alleged had been mailed with Appellee's first billing statement. The circuit court denied the motion to compel arbitration and granted Appellee's motion for class certification. The Supreme Court affirmed, holding (1) the circuit court correctly denied DIRECTV's motion to compel Appellee to arbitration on the basis that Appellee cancelled her service so quickly she did not assent to the arbitration agreement by her continued use of service; and (2) there was no merit to DIRECTV's arguments for reversal of the class-certification order.View "DIRECTV, Inc. v. Murray" on Justia Law

Certain individuals who worked for American Chemical Society (ACS) founded Leadscope Inc. and later received a patent for technology similar to that on which they worked while at ACS. ACS filed a lawsuit against Leadscope. A newspaper subsequently published an article about the suit quoting ACS's counsel. In pertinent part, the jury returned verdicts in favor of Leadscope on its counterclaims for defamation and unfair competition. The court of appeals affirmed. The Supreme Court (1) upheld the appellate court's decision affirming the trial court's denial of ACS's motion for judgment notwithstanding the verdict (JNOV) on the unfair competition claim, holding (i) a party alleging a claim for unfair competition must show the action is baseless and the opposing party had the intent to injure the party's ability to be competitive, and (ii) the jury instructions here did not meet that test, but the jury could not reasonably have made any other determination with proper instructions; and (2) reversed the appellate court's finding that the trial court properly overruled ACS's motion for JNOV on Leadscope's counterclaim for defamation, holding (i) ACS's statements were not defamatory, and (ii) a client is vicariously liable for its attorney's defamatory statements only if the client ratified the statements.View "Am. Chem. Soc'y v. Leadscope, Inc." on Justia Law

These companion appeals arose out of a dispute between a government contractor, Preferred Systems Solutions, Inc. (PSS) and one of its subcontractors, GP Consulting, LLC (GP). PSS sued GP following GP's termination of its contract with PSS and its commencement of a subsequent contract with a PSS competitor. PSS alleged breach of contract, misappropriation of trade secrets, and tortious interference with contract, seeking injunctive as well as monetary relief. PSS was ultimately awarded $172,396 in compensatory damages based on the circuit court's finding that GP breached the noncompete clause in the parties' contract. Both parties appealed. The Supreme Court affirmed, holding that the circuit court did not err in (1) awarding damages to PSS for lost profits as a result of GP's breach of the noncompete clause; and (2) refusing to grant PSS injunctive relief, in concluding that PSS failed to prove tortious interference, and in dismissing PSS' trade secret claim.View "Preferred Sys. Solutions, Inc. v. GP Consulting, LLC" on Justia Law