Go-Graphics of New Orleans, LLC v. Regional Transit Authority and Transdev Services, Inc. F/K/A Veolia Transportation Services, Inc.

Summary

This is a dissenting opinion by Judge Ervin-Knott in an appeal concerning Go-Graphics of New Orleans, LLC’s claims against the Regional Transit Authority and Transdev Services, Inc. The dissent would affirm summary judgment dismissing Transdev, reasoning that the Regional Transit Authority ratified the contract and that Go-Graphics lacked a contractual claim against Transdev. The dissent further concludes that the detrimental-reliance claim was tortious and prescribed under the applicable one-year period.

Holdings

1. The district court properly granted summary judgment on the breach-of-contract claim because Transdev was not a party to the contract, there was no evidence that it exceeded its authority as the RTA's agent, and the RTA ratified the contract.
2. The detrimental-reliance claim was prescribed because it was tortious in nature and was filed more than one year after the alleged breach and the contract's expiration.

Questions Presented

1. Whether the district court erred in granting summary judgment dismissing Go-Graphics's breach-of-contract claim against Transdev when Transdev was not a party to the contract and the RTA allegedly ratified any actions taken by Transdev.
2. Whether Go-Graphics's detrimental-reliance claim against Transdev was prescribed because it was tortious in nature and was filed more than one year after the alleged breach and contract expiration.

Disposition

affirmed