Justia U.S. 10th Circuit Court of Appeals Opinion Summaries

Two infrastructure companies formed a joint venture to bid on a Colorado highway express lane project, relying on engineering designs from a subsidiary of one partner. After winning the contract, the joint venture entered a subcontract with the engineering firm that incorporated many of their earlier terms but added a liability cap. During the project, disputes arose over the design work, resulting in multiple redesigns and delays. The engineering firm submitted change orders for additional work, but the joint venture either failed to process them according to contract procedures or “shelved” them as litigation began.The engineering firm sued the joint venture in the United States District Court for the District of Colorado, claiming breach of contract and unjust enrichment. The joint venture counterclaimed for breach of both the subcontract and the original teaming agreement, and later added a negligent misrepresentation claim. The district court dismissed the negligent misrepresentation counterclaim under the economic-loss rule and later granted summary judgment to the engineering firm on the teaming agreement counterclaim, holding that the subcontract superseded the earlier agreement and imposed a liability cap. The joint venture sought to add fraud counterclaims more than a year after the final pretrial order, but the district court denied this as untimely and prejudicial. The court also rejected the joint venture’s attempt to concede liability and assume the plaintiff’s role at trial, and denied its Rule 50 motions.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s rulings. The appellate court held that the district court did not err in denying the joint venture’s various motions, including its attempt to add new counterclaims, to instruct the jury on an implied duty of good faith and fair dealing, or to enter judgment against itself. The Tenth Circuit affirmed the district court’s judgment in favor of the engineering firm on all claims and counterclaims. View "AECOM Technical Services v. Flatiron | AECOM" on Justia Law

The dispute centers on a coal mining lease in Wyoming originally executed in 1986 between Rock Springs Royalty Company and Bridger Coal Company. Under this lease, Bridger gained exclusive rights to mine coal from a specified area (the “Nine Mile Lease”) and was required to mine at least forty-five percent of the total coal from both the leased lands and “Adjoining Lands” every five years. Bridger was obligated to pay production royalties based on actual coal mined or, if it failed to meet the threshold, advance royalties based on projected production. For nearly thirty years, payments proceeded without issue. In 2020, Bridger, anticipating it would not meet the production threshold, paid an advance royalty, but Wildcat Coal LLC, which had succeeded as lessor, objected to the calculation, particularly the definition of “Adjoining Lands.” Bridger then withheld future royalties to recover what it claimed was an overpayment, prompting Wildcat to sue for breach of contract.The United States District Court for the District of Wyoming granted summary judgment for Wildcat, finding Bridger’s definition of “Adjoining Lands” was incorrect and that the term included both public and private lands as well as surface and underground mining. In a footnote, the district court sua sponte required Bridger to recalculate all royalties paid since 1986, although neither party had requested this. Bridger subsequently moved to correct the order, arguing that a thirty-six-month protest provision in the lease barred recalculation for earlier years, but the district court denied the motion.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The Tenth Circuit held that the lease’s protest provision precluded recalculation of royalties for payments made before 2016, reversed the district court’s order requiring recalculation from 1986, affirmed the district court’s interpretation of “Adjoining Lands,” and remanded for proceedings consistent with its opinion. View "Wildcat Coal v. Pacific Minerals" on Justia Law

Between 2007 and 2011, Michael Jensen sexually abused multiple children in Martinsburg, West Virginia. Jensen’s parents and grandfather held significant positions within the Church of Jesus Christ of Latter-Day Saints. Several of Jensen’s victims later sued the Church in West Virginia state court, alleging that the Church failed to take reasonable precautions to prevent Jensen’s abuse, including failing to report suspected abuse and failing to supervise or warn families about Jensen’s prior conduct. Before a verdict was reached, the Church settled with the remaining minor plaintiffs and their families.Following settlement, the Church sought coverage from two of its insurers, National Union Fire Insurance Company of Pittsburgh, PA, and ACE Property and Casualty Insurance Company, for defense and settlement costs. Both insurers refused to pay, prompting the Church to file suit in the United States District Court for the District of Utah, claiming breach of contract and breach of the implied covenant of good faith. The central issue became whether the underlying events constituted a single “occurrence” or multiple “occurrences” under the insurance policies, which would determine if the Church’s settlements met the policies’ retained limits required for coverage. The district court granted summary judgment to the insurers, holding that each instance of abuse was a separate occurrence and, therefore, the retained limits were not met for any single occurrence.The United States Court of Appeals for the Tenth Circuit reviewed the case and reversed the district court’s grant of summary judgment. The Tenth Circuit held that the insurance policies’ definitions of “occurrence” were ambiguous and that the Church’s interpretation—that its alleged negligence constituted a single occurrence—was reasonable. Under Utah law, ambiguities in insurance contracts must be construed in favor of coverage. The case was remanded for further proceedings consistent with this interpretation. View "Church of Jesus Christ of Latter-Day Saints v. National Union Fire Insurance Company of Pittsburg" on Justia Law

The plaintiff participated in a clinical trial for an experimental COVID-19 vaccine manufactured by AstraZeneca in November 2020. Before receiving the vaccine, she signed an informed-consent form stating that AstraZeneca would compensate her for injuries caused by the vaccine, including providing medical care and reimbursement, and that the company had an insurance policy to cover such costs. The form also disclosed that federal law may limit her right to sue for vaccine-related injuries, referencing the Public Readiness and Emergency Preparedness Act (PREP Act), which provides broad immunity to vaccine manufacturers during a public health emergency.After suffering debilitating medical injuries from the vaccine, the plaintiff requested compensation and care from AstraZeneca, which was denied. She then filed suit in the United States District Court for the District of Utah, alleging breach of contract and breach of the contractual duty of good faith and fair dealing. AstraZeneca moved to dismiss the complaint, arguing that the PREP Act immunized it from liability. The district court denied the motion, holding that the PREP Act’s immunity provision applies only to tort claims, not to contract-based claims. The court further reserved judgment on whether AstraZeneca had waived its statutory immunity in the informed-consent form.The United States Court of Appeals for the Tenth Circuit reviewed the case and reversed the district court’s ruling. The appellate court held that the PREP Act’s immunity provision applies to “all claims for loss,” including those arising from breach of contract, provided they bear a causal relationship to the administration or use of a covered countermeasure like a vaccine. The court remanded the case for the district court to consider whether AstraZeneca waived immunity in the informed-consent form. View "Dressen v. AstraZeneca AB" on Justia Law

Several individuals who own royalty interests in the Kansas Hugoton Gas Field brought a putative class action against two energy companies. Their claims are based on an alleged breach of a 2008 class action settlement agreement, which had resolved earlier disputes about underpayment of royalties by one of the companies. The 2008 settlement required limits on certain deductions from royalty payments and specified that its terms would bind successors, assigns, and related entities. In 2014, one defendant acquired assets from the other and continued making royalty payments. Plaintiffs allege the acquiring company violated the settlement by taking improper deductions after the acquisition.The plaintiffs initially sought to enforce the settlement in Kansas state court, but the District Court of Stevens County determined the judgment had become dormant and unenforceable. Plaintiffs appealed that ruling, and while the appeal was pending, they filed this federal class action complaint in the United States District Court for the District of Kansas. The district court denied defendants’ motions to dismiss but later denied class certification. The district court found that the proposed class was not ascertainable because identifying class members would require individualized title review and that other Rule 23 requirements were not satisfied.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision. The appellate court clarified that, under its recent precedent, class ascertainability does not require administrative feasibility—only an objectively and clearly defined class. The court found the proposed class ascertainable, that common questions predominated, and that the plaintiffs satisfied all Rule 23 requirements. The Tenth Circuit reversed the district court’s denial of class certification and remanded with instructions to certify the putative class. View "Rider v. Oxy USA" on Justia Law

A property owner, Gary Binning, purchased land in Wyoming that was subject to a conservation easement held by The Nature Conservancy (TNC). This easement restricted the types of structures that could be built on the property, allowing only one single-family residential structure per parcel. Binning sought to build a guest house in addition to a main house, but TNC denied his request, citing the easement’s terms. This dispute led to litigation, and the Wyoming Supreme Court ultimately ruled that the easement did not permit construction of any guest house or secondary residential structure.Following this decision, Binning met with TNC’s Wyoming state director, Hayley Mortimer, who, according to Binning, suggested during an informal lunch meeting that he could build a structure accommodating overnight guests as long as it was not called a “guest house” and did not include a kitchen. Binning later sought approval for new building plans, but TNC rejected them, and Mortimer’s subsequent written communication did not confirm any such oral promise. Binning then filed suit in the United States District Court for the District of Wyoming, asserting a claim of promissory estoppel based on Mortimer’s alleged statements.The district court granted summary judgment in favor of TNC, finding that Binning failed to establish the required elements of promissory estoppel under Wyoming law: a clear and definite promise, reasonable reliance, and that enforcement was necessary to avoid injustice. On appeal, the United States Court of Appeals for the Tenth Circuit agreed, holding that Mortimer’s alleged statements were not sufficiently clear and definite to constitute a promise, any reliance by Binning was unreasonable under the circumstances, and no injustice would result from refusing enforcement. The Tenth Circuit affirmed the district court’s judgment. View "Four B Properties v. The Nature Conservancy" on Justia Law

This case involves a class action dispute over late payments of oil proceeds to royalty and working interest owners in Oklahoma. The plaintiff, an Oklahoma landowner with royalty interests in three oil wells, alleged that Sunoco, Inc. and Sunoco Partners Marketing & Terminals, L.P. failed to pay statutory interest on late payments as required by Oklahoma’s Production Revenue Standards Act (PRSA). The PRSA mandates that first purchasers of oil must pay proceeds within strict timeframes and include 12 percent interest on any late payments. The class was defined to include all owners who received late payments from Sunoco without the required interest.After Sunoco removed the case to the United States District Court for the Eastern District of Oklahoma, the court certified the class in 2019, finding common questions predominated, including whether Sunoco owed interest on untimely payments and whether a demand was required. The district court granted partial summary judgment on liability for the PRSA claim, and after a bench trial, awarded the class over $103 million in actual damages (including prejudgment interest) and $75 million in punitive damages. Sunoco appealed, challenging class certification, standing for certain class members, the calculation of prejudgment interest, and the punitive damages award. The Tenth Circuit previously remanded for clarification on damages allocation for unidentified owners, which the district court addressed.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s rulings on class certification, ascertainability, standing, and the award of actual damages including prejudgment interest. The court held that the PRSA requires automatic payment of statutory interest on late payments, and that prejudgment interest should be compounded until paid. However, the Tenth Circuit vacated the punitive damages award, holding that punitive damages are not available for breach of contract claims under Oklahoma law when the only claim proven was a PRSA violation. The case was remanded for amendment of the judgment consistent with this opinion. View "Cline v. Sunoco" on Justia Law

A marketing and e-commerce company based in Nevada provided services for the Kanye 2020 presidential campaign at the request of a group of Arizona-based political consultants (the Lincoln defendants). The company began work without a written contract, relying on assurances that terms would be formalized later. It created campaign materials, built a website, and managed digital operations, but was never paid for its work. The company sued Kanye 2020 and the Lincoln defendants in the United States District Court for the District of Wyoming, alleging breach of contract, breach of the implied duty of good faith and fair dealing, and unjust enrichment.The District of Wyoming found it lacked personal jurisdiction over the Lincoln defendants and transferred those claims to the District of Arizona under 28 U.S.C. § 1631, citing concerns about potential statute of limitations issues. The court dismissed the claims against Kanye 2020 for failure to state a claim, but did so without prejudice. Kanye 2020 moved for reconsideration, seeking dismissal with prejudice, but the Wyoming court declined, stating it no longer had jurisdiction after the transfer.On appeal, the United States Court of Appeals for the Tenth Circuit held that it lacked jurisdiction to review the interlocutory transfer order. The court affirmed the dismissal of the contract claims against Kanye 2020, finding the complaint failed to plausibly allege the existence of an oral or implied contract or unjust enrichment, as there were insufficient communications or notice to Kanye 2020 regarding payment expectations. However, the Tenth Circuit held that the district court erred in concluding it lacked jurisdiction to consider Kanye 2020’s motion for reconsideration. The case was remanded for the district court to determine whether the dismissal of the claims against Kanye 2020 should be with prejudice. View "SeedX v. Lincoln Strategy" on Justia Law

Several healthcare employees in Colorado, including those at the University of Colorado Hospital Authority and South Denver Cardiology Associates, were terminated after refusing to comply with their employers’ COVID-19 vaccination mandates. These mandates, implemented in 2021, required employees to either be vaccinated or obtain a medical or religious exemption. The plaintiffs declined vaccination and did not seek exemptions, resulting in their dismissal.Following their terminations, the plaintiffs filed separate lawsuits in the United States District Court for the District of Colorado, asserting nearly identical claims. They alleged violations of statutory, constitutional, and contractual rights, including claims under 42 U.S.C. § 1983, state-law breach of contract and tort claims, and an implied private right of action under the Food, Drug, and Cosmetic Act. The defendants moved to dismiss on grounds such as sovereign immunity, qualified immunity, and failure to state a claim. The district courts dismissed all claims, finding that the plaintiffs had not adequately pled any viable legal theory. The courts also denied the plaintiffs’ requests to amend their complaints after judgment was entered.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissals de novo. The court held that none of the statutes cited by the plaintiffs—including the Emergency Use Authorization statute, the PREP Act, and 10 U.S.C. § 980—unambiguously conferred individual rights enforceable under § 1983. The court also found that the constitutional claims, including those based on due process and equal protection, were not adequately pled and that the breach of contract claim was waived for lack of argument. The Tenth Circuit affirmed the district courts’ judgments, holding that the plaintiffs failed to state any claim upon which relief could be granted and that the lower courts did not abuse their discretion in denying leave to amend. View "Timken v. South Denver Cardiology Associates" on Justia Law

ADA Carbon Solutions (Red River), LLC ("ADA") filed a lawsuit against Atlas Carbon, LLC ("Atlas") in the United States District Court for the District of Wyoming, alleging breach of contract and breach of the implied covenant of good faith and fair dealing under Wyoming law. ADA claimed that Atlas breached their contract for the sale of activated carbon by improperly invoking the "Force Majeure" clause and failing to supply the agreed-upon quantity of carbon. ADA filed an amended complaint asserting diversity jurisdiction under 28 U.S.C. § 1332(a)(1).The district court accepted jurisdiction and, after a bench trial, awarded ADA $76,000 in damages. ADA appealed the district court's judgment, dissatisfied with the method for calculating damages. During the appeal, the Tenth Circuit Court of Appeals identified potential jurisdictional defects, specifically regarding the complete diversity of citizenship between the parties. The court ordered supplemental briefing to clarify the citizenship of Atlas's members, including trusts and limited partnerships involved.The Tenth Circuit Court of Appeals found that it lacked sufficient information to determine whether complete diversity of citizenship existed at the time of filing. The court noted that Atlas's identification of its members, including trusts and limited partnerships, was incomplete and did not provide adequate information about their citizenship. Consequently, the court vacated the judgment and remanded the case to the district court to make the necessary factual findings to determine whether it had diversity jurisdiction under 28 U.S.C. § 1332. The district court was instructed to analyze the citizenship of all members of ADA and Atlas, tracing through all layers of ownership to ensure complete diversity. View "ADA Carbon Solutions (Red River) v. Atlas Carbon" on Justia Law