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Terry Barr Sales, L.L.C. v. Amcast Industrial Corp.

Citation: 107 F. App'x 629Docket: No. 01-1097

Court: Court of Appeals for the Sixth Circuit; August 25, 2004; Federal Appellate Court

Narrative Opinion Summary

This case involves a dispute between Terry Barr Sales, L.L.C. and Terry Barr and Ameast Industrial Corporation regarding the alleged breach of a Manufacturer’s Representative Agreement. The plaintiffs argued that Ameast wrongfully terminated the contract and failed to pay post-termination commissions calculated on a sliding scale, as specified in the agreement. They also sought reformation of the contract and claimed unjust enrichment. Additionally, Terry Barr invoked the Michigan Sales Representative Commission Act, seeking double damages for non-payment of commissions. The district court granted summary judgment for Ameast on several claims but ruled in favor of Terry Barr on the timely payment of commissions and double damages, holding that evidence of bad faith was unnecessary under the Act. Both parties appealed the decision. The appellate court affirmed the district court's judgment, finding the legal principles correctly applied and noting the Michigan Supreme Court's clarification that intentional non-payment suffices for the imposition of double damages under the statute. The appellate court found the district court's opinion thorough, negating the need for a detailed appellate opinion.

Legal Issues Addressed

Breach of Contract and Termination

Application: The claim was based on the alleged wrongful termination of a Manufacturer’s Representative Agreement and failure to pay commissions as agreed.

Reasoning: Terry Barr Sales, L.L.C. and Terry Barr initiated legal action against Ameast Industrial Corporation, alleging breach of the Manufacturer’s Representative Agreement due to the contract's termination, failure to pay post-termination commissions as stipulated in the agreement, and unjust enrichment.

Judicial Review and Appellate Confirmation

Application: The appellate court confirmed the district court's judgment, agreeing that the legal principles were correctly applied and no detailed opinion was necessary.

Reasoning: The appellate court agreed with the district court's findings, confirming that no genuine issues of material fact required trial and that the law was correctly applied.

Michigan Sales Representative Commission Act

Application: The plaintiff sought double damages under the Act for failure to pay commissions, which the court upheld without requiring evidence of bad faith.

Reasoning: Terry Barr also cited violations of the Michigan Sales Representative Commission Act, seeking double damages...the Michigan Supreme Court clarified...that intentional failure to pay suffices for penalties under the statute.

Summary Judgment in Contract Disputes

Application: The district court ruled on multiple claims via summary judgment, finding no genuine issues of material fact, a decision upheld by the appellate court.

Reasoning: The district court granted summary judgment to Ameast on claims of breach of contract, commission calculation, contract reformation, and unjust enrichment, while ruling in favor of Terry Barr regarding the monthly payment of commissions and entitlement to double damages under the Michigan Act.