Justia Kansas Supreme Court Opinion SummariesArticles Posted in Contracts
Hamel v. Hamel
This appeal arose over the administration of a Trust between Lawrence, the Trust's beneficiary, and the Trust's trustees, Dennis and Leona (collectively, Trustees). Lawrence moved to set aside a contract for deed executed between Dennis and his wife and the Trustees for the sale of farmland owned by the Trust and also sought to remove the Trustees, alleging they engaged in self-dealing and breached their fiduciary duties. The district court concluded (1) the Trust permitted the Trustees to finance the sale of the farmland to Dennis under the terms set forth in the contract for deed; and (2) Lawrence violated the Trust's no-contest clause by challenging the Trustee's sale of the farmland to Dennis, which required Lawrence's disinheritance. The Supreme Court reversed the district court's ruling regarding the Trustees' authority to finance the sale of the farm and its enforcement of the no-contest clause against Lawrence, holding (1) the Trustees' execution of the contract for deed violated the terms of the Trust; and (2) Lawrence had probable cause to challenge the Trustees' sale of the farm to Dennis. Remanded. View "Hamel v. Hamel" on Justia Law
Waste Connections of Kan., Inc. v. Ritchie Corp.
Defendant Ritchie Corporation conveyed title to a tract of land a waste systems corporation (BFI). Ritchie and BFI entered into an escrow agreement that entitled BFI to operate the property as a nonhazardous waste transfer station for thirty-five years. Ritchie granted BFI a right of first refusal to buy the transfer station from Ritchie. BFI later assigned its title and interest in the escrow agreement to Plaintiff Waste Connections, which began operating the transfer station. Later, a third party agreed to buy the transfer station and an adjoining landfill. Waste Connections asserted its right of first refusal to purchase the transfer station. Waste Connections and Ritchie subsequently disputed the proper price owed under the escrow agreement - $1.45 million or $2 million. The district court entered summary judgment in favor of Ritchie. The court of appeals reversed. The Supreme Court reversed, holding that because genuine issues of material fact remained on Waste Connections' breach of contract action against Ritchie, summary judgment for either party was inappropriate. View "Waste Connections of Kan., Inc. v. Ritchie Corp." on Justia Law
State, ex rel. Hecht v. City of Topeka
The City of Topeka attempted to purchase a new police helicopter from Schreib-Air, Inc. with financing by Municipal Services Group, Inc. (MSG) After a lease-purchase agreement was signed, the State filed suit seeking a declaratory judgment that the agreement between the City and Schreib-Air was invalid, void ab initio, and ultra vires because the lease-purchase agreement failed to comply with the cash-basis law. Although the helicopter was never actually purchased, the district court held that the transactions with Schreib-Air and MSG violated the cash-basis law and ordered that any money given to MSG or Schreib-Air related to the helicopter purchase was to be returned. The Supreme Court affirmed, holding that Schreib-Air's agreement with the City was void when entered into because the contract was made in violation of the cash-basis law and, consequently, the contract was unenforceable. View "State, ex rel. Hecht v. City of Topeka" on Justia Law
Coulter v. Anadarko Petroleum Corp.
Plaintiffs in this case were royalty owners entitled to receive a share of the production of natural gas in a gas field. Plaintiffs brought a class action against Anadarko Petroleum Corporation (APC) and its affiliates challenging the manner in which APC was paying royalties on natural gas production under the respective oil and gas leases. Timothy Coulter represented the plaintiff class and negotiated a settlement agreement. More than 6,000 members made up the settlement class, one of whom was Stan Boles. Boles objected to the amended class certification and the class settlement agreement negotiated by Coulter. The district court approved the settlement despite Boles' objection. Boles appealed. The Supreme Court affirmed, holding the district court did not abuse its discretion in assessing the adequacy of the class representation or the character of the settlement agreement. View "Coulter v. Anadarko Petroleum Corp." on Justia Law
Rucker v. DeLay
This was a quiet title action challenging a claimed interest to oil and gas rights reserved in 1924 when the landowners sold the surface and mineral estate but kept for themselves and their heirs what was described as a portion of the landowners' one-eighth interest in the oil, gas, or other minerals that might later be developed. The district court and court of appeals held that this reservation was a royalty interest and invalidated it under the rule against perpetuities. The Supreme Court reversed, holding that the royalty interest was not void under the rule against perpetuities because it was reserved in the grantors. View "Rucker v. DeLay" on Justia Law
Schoenholz v. Hinzman
Defendant entered into an oral agreement with his sister, Defendant, for the bailment of farm animals and farm equipment on her land. After their cooperative effort to breed horses broke down, Defendant sold her farm and the horses. Plaintiff subsequently retrieved most of his equipment from the farm and sued Defendant for conversion and breach of the bailment contract. Defendant counterclaimed for the expenses of maintaining the equipment and caring for the horses. The district court awarded no damages. The court of appeals affirmed the rulings against Plaintiff but found the district court erred in denying sanctions against Plaintiff. The Supreme Court reversed in part, holding (1) Plaintiffs' action in tort was not barred by the statute of limitations; (2) the district court erred by rejecting Plaintiff's claim for conversion; (3) the court of appeals correctly found that the district court abused its discretion by refusing to award attorney fees as a sanction, but the question of attorney fees was remanded to the district court for determining the amount of fees to be awarded. View "Schoenholz v. Hinzman" on Justia Law
In re Marriage of Hall
This appeal raised the issue of whether a district court can order a child support obligor to cooperate with a child support obligee in the obligee's efforts to obtain insurance on the obligor's life if the obligor objects to the issuance of the life insurance policy. Here, despite the obligor's objection, the district court ordered the obligor to cooperate with the obligee's attempts to obtain insurance on the obligor's life at the obligee's own expense. The court of appeals affirmed. The Supreme Court reversed, holding that a district court cannot issue such an order because the order would be contrary to public policy as expressed by the Kansas Legislature in Kan. Stat. Ann. 40-453(a), which provides that an insurable interest does not exist if a person whose life is insured makes a written request for the termination or nonrenewal of the policy. View "In re Marriage of Hall" on Justia Law
Law v. Law Co. Bldg. Assocs.
At issue in this appeal was whether the court of appeals erred in holding that an action seeking reformation of an executory contract does not accrue until a party discovers a mutual mistake in the contract language. The district court granted summary judgment in favor of Defendants, finding that Plaintiff's reformation claim was barred by Kan. Stat. Ann. 60-511(1) because the mutual mistake occurred when the contract was executed, which was more than five years before this case was filed. The court of appeals reversed. The Supreme Court reversed the judgment of the court of appeals, holding (1) a cause of action for reformation of a contract based on an alleged mutual mistake accrues when the mistake is made, not when the mutual mistake is discovered; and (2) the application of these rules does not depend on whether a contract is executed or executory, and the rules do not vary just because the contract relates to the title of real property. View "Law v. Law Co. Bldg. Assocs." on Justia Law
Aeroflex Wichita, Inc. v. Filardo
After allowing discovery on the issue of whether Kansas courts could exercise personal jurisdiction over some of the defendants in this case, the district court granted defendant Tel-Instrument Electronics Corp.'s (TIC) motion to dismiss for lack of personal jurisdiction. At issue on interlocutory appeal was the correct standard for judging a motion to dismiss for lack of personal jurisdiction when that motion is decided after discovery but without an evidentiary hearing. The Supreme Court reversed, holding (1) plaintiff Aeroflex Wichita, as the party with the ultimate burden of establishing jurisdiction and as the party responding to a motion to dismiss presented to the court without an evidentiary hearing, need only establish a prima facie basis for jurisdiction; (2) in determining if that prima facie burden has been met, a district court should view factual disputes in the light most favorable to the nonmoving party, and an appellate court applies the same standard de novo; and (3) in this case, the district court erred erred by weighing the evidence rather than granting all favorable inferences to Aeroflex, and Aeroflex presented a prima facie case of jurisdiction based on a conspiracy between TIC and its codefendants, over whom the court had jurisdiction. View "Aeroflex Wichita, Inc. v. Filardo" on Justia Law
Miller v. FW Commercial Props.
Oscar Armendariz, the owner of a tract of land subject to eminent domain proceedings, appealed the district court's order determining the final distribution of an appraisers' award. Armedariz contended the district court erred in distributing a portion of the award based on quantum meruit to Vernon Jarboe, the attorney for Richard and Angela Britt, who were formerly interested parties to the eminent domain proceeding. The Supreme Court reversed the district court's award, holding that the district court lacked statutory authority to award fees to Jarboe. Remanded with directions to enter an order distributing the entire amount of the award in favor of Armendariz. View "Miller v. FW Commercial Props. " on Justia Law