Life Investors Ins. Co. v. Fed. City Region, Inc., No. 11-3518 (8th Cir. 2012)
Annotate this CaseLife Investors Insurance Co. of America filed a breach of contract action against John Corrado and Federal City Region, Inc. (collectively, Carrado) for allegedly breaching a settlement agreement that existed between the parties. Life Investors also sought a declaratory judgment that it had not violated the agreement and that if the agreement was not valid, then Corrado was bound by the original agreement between the parties. The district court determined the agreement was enforceable and that Corrado had violated it. Accordingly, the court granted summary judgment in favor of Life Investors. The Eighth Circuit Court of Appeals reversed the judgment and remanded, holding (1) the district court erred by extending the doctrine of ratification based on inapplicable Iowa case law and Restatement sections to a case such as this where Corrado did not argue a circumstance invalidated Corrado's signature on the written contract but instead that Corrado never signed the contract; and (2) accordingly, the district court erred in granting summary judgment to Life Investors.
Court Description: Civil Case - diversity. District court's grant of summary judgment on breach of contract claim is reversed, as the district court failed to analyze whether the settlement agreement at issue was authenticated and whether Corrado was bound by the settlement agreement . The district court erred by extending the doctrine of ratification based on inapplicable Iowa case law.
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