Hetland v. LendingTree, LLC
- Jacquelyn Corley
- 3:19-cv-02288
- U.S. District Court · Northern District of California
- 2
In Hetland v. LendingTree, Judge Corley denied Hetland’s request to decide the choice-of-law issue separately before summary judgment.
C. Johannes Hetland and LendingTree, LLC, particularly their briefing and the timing of the choice-of-law issue in relation to summary judgment.
What happened
In Hetland v. LendingTree, LLC, C. Johannes Hetland asked the court to decide first whether California or Delaware law governs his claims for breach of contract, breach of the duty of good faith and fair dealing, unjust enrichment, and promissory fraud.
The court said choice-of-law questions are well suited to resolution during summary judgment and that deciding the issue then would be more efficient. It also noted that the parties could agree to extend Hetland’s time to respond or could ask permission for a longer filing.
The court denied Hetland’s request to separate the choice-of-law issue from the summary-judgment process. Judge Jacqueline Scott Corley signed the order.
The detailed version
- Hetland v. LendingTree, LLC · No. 3:19-cv-02288
- Jacquelyn Corley
- Dec. 10, 2020
Background
C. Johannes Hetland filed a letter brief asking the court to bifurcate, or separate, a choice-of-law question from the rest of the case. The question was whether California or Delaware law applies to his claims against LendingTree, LLC for breach of contract, breach of the covenant of good faith and fair dealing, unjust enrichment, and promissory fraud. Hetland asked the court to decide that question before LendingTree submitted its motion for summary judgment.
Court’s reasoning
The court explained that choice-of-law determinations are legal questions that are well suited to summary judgment. It also found that resolving the issue during the summary-judgment stage would be more efficient because it would reduce the number of briefs required from the parties and the court. The court rejected Hetland’s concern that responding to both issues at once would cause prejudice, noting that the parties could agree to extend his opposition deadline or ask for permission to file an overlength opposition.
Ruling
The court denied Hetland’s request for bifurcation. This order did not decide whether California or Delaware law applies, and it did not rule on the anticipated summary-judgment motion. Judge Jacqueline Scott Corley issued the order on December 10, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.