Little Rock Sun Times, LLC v. Mediaspace Solutions, Inc.
- Donovan Frank
- 0:21-cv-01138
- U.S. District Court · District of Minnesota
- 9
In Little Rock Sun Times v. Mediaspace, Judge Frank dismissed two claims without prejudice but denied dismissal of the remaining claims.
Little Rock Sun Times, LLC may continue pursuing its breach-of-contract, quantum-meruit, and unjust-enrichment claims against Mediaspace Solutions, Inc.; the account-stated and good-faith-and-fair-dealing claims were dismissed without prejudice.
What happened
Little Rock Sun Times, LLC sued Mediaspace Solutions, Inc., seeking payment for advertisements that ran in the newspaper from November 2017 through March 2018. It brought claims involving an alleged advertising contract and payment for the advertising services.
Mediaspace argued that it had paid the proper party and that the complaint did not plausibly state claims. Little Rock Sun Times disputed those facts and argued that its claims were adequately supported. The court found that the parties’ disagreements about the contract, payment, and the authority of a third party could not be resolved at this stage.
Judge Frank granted in part and denied in part Mediaspace’s motion to dismiss. He dismissed the account-stated and good-faith-and-fair-dealing claims without prejudice, but denied the motion as to the breach-of-contract, quantum-meruit, and unjust-enrichment claims.
The detailed version
- Little Rock Sun Times, LLC v. Mediaspace Solutions, Inc. · No. 0:21-cv-01138
- Donovan Frank
- Oct. 22, 2021
Background
Little Rock Sun Times, LLC sued Mediaspace Solutions, Inc. over payment for tobacco advertisements that allegedly ran in the Little Rock Sun newspaper and online from November 2017 through March 2018. The complaint alleged that Mediaspace was retained to arrange the court-ordered advertising and handle payment, contracted for the advertising, received payment instructions directing payment to Little Rock Sun, and failed to pay Little Rock Sun’s $99,400 invoice.
Mediaspace asserted that it paid $99,400 by check to Feldean Group, LLC, the parent company of Centipede Group, LLC. Mediaspace said that Centipede and Dr. Casey Roberts were authorized to handle the advertising. Little Rock Sun disputed that Dr. Roberts or Centipede had authority to bill or collect payment on its behalf and disputed whether Mediaspace paid the proper party.
Little Rock Sun asserted claims for breach of contract, unjust enrichment, quantum meruit, account stated, and breach of the duty of good faith and fair dealing. Mediaspace moved to dismiss the entire case with prejudice.
Legal standard and analysis
The court applied the Rule 12(b)(6) standard, which asks whether the complaint contains enough factual allegations to state a legally plausible claim. At this stage, the court generally assumes the complaint’s factual allegations are true and draws reasonable inferences for the plaintiff, but it does not accept unsupported legal conclusions.
The court dismissed the account-stated and good-faith-and-fair-dealing claims without prejudice because Little Rock Sun did not respond to Mediaspace’s arguments about those claims or provide a legal basis for them.
The court concluded that Little Rock Sun had sufficiently alleged its remaining claims. For breach of contract, the complaint alleged a valid contract, Little Rock Sun’s performance, Mediaspace’s breach, and resulting damages. The complaint also alleged that Mediaspace received the value of the advertising and should pay for it, supporting the alternative claims for quantum meruit and unjust enrichment.
The court declined to resolve the parties’ factual disputes on a motion to dismiss. Those disputes included who was a party to the contract, whether Mediaspace paid the proper party, what document expressed the contract, and whether Little Rock Sun authorized Centipede to invoice or collect payment. The court also declined to convert the motion into a summary-judgment motion and stated that a properly filed summary-judgment motion could be considered after discovery.
Order
The court granted in part and denied in part Mediaspace’s motion to dismiss. It granted the motion as to Count Three, account stated, and Count Five, breach of the duty of good faith and fair dealing; those counts were dismissed without prejudice. It denied the motion as to all other claims, including breach of contract, quantum meruit, and unjust enrichment.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.