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Keywords

damagesappealtrialverdictwilljury trial

damagesappealtrialverdictwillcitizenship

Related Cases

Gasperini v. Center for Humanities, Inc., 518 U.S. 415, 116 S.Ct. 2211, 135 L.Ed.2d 659, 64 USLW 4607, 96 Cal. Daily Op. Serv. 4548, 96 Daily Journal D.A.R. 7338

Facts

William Gasperini, a journalist, loaned 300 original slide transparencies to the Center for Humanities, Inc. for an educational project. After the Center lost the transparencies, Gasperini sued in federal court, where the jury awarded him $450,000 based on an industry standard of $1,500 per transparency. The Center contested the verdict as excessive, leading to an appeal and subsequent review by the Court of Appeals, which found the award to materially deviate from reasonable compensation under New York law.

Petitioner William Gasperini, a journalist for CBS News and the Christian Science Monitor, began reporting on events in Central America in 1984. He earned his living primarily in radio and print media and only occasionally sold his photographic work. During the course of his seven-year stint in Central America, Gasperini took over 5,000 slide transparencies, depicting active war zones, political leaders, and scenes from daily life.

Issue

The main legal issue was whether New York's law governing the review of jury verdicts for excessiveness could be applied in federal court without violating the Seventh Amendment's reexamination clause.

The compatibility of these provisions, in an action based on New York law but tried in federal court by reason of the parties' diverse citizenship, is the issue we confront in this case.

Rule

Under New York law, specifically CPLR § 5501(c), appellate courts can review jury verdicts and order new trials if the award deviates materially from what would be reasonable compensation. The Seventh Amendment preserves the right to a jury trial and limits the reexamination of facts tried by a jury.

Under the law of New York, appellate courts are empowered to review the size of jury verdicts and to order new trials when the jury's award 'deviates materially from what would be reasonable compensation.' N.Y. Civ. Prac. Law and Rules (CPLR) § 5501(c).

Analysis

The Supreme Court analyzed the compatibility of New York's compensation review standard with the Seventh Amendment. It concluded that applying the 'deviates materially' standard in federal court does not infringe upon the jury's role, as long as the federal trial court retains the authority to review the jury's verdict for abuse of discretion. The Court emphasized that the federal district court is capable of applying New York's standard without undermining the federal judicial system.

The Court therefore agrees with the Second Circuit that New York's check on excessive damages warrants application in federal court, for Erie’s doctrine precludes a recovery in federal court significantly larger than the recovery that would have been tolerated in state court.

Conclusion

The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing that the trial judge should apply the 'deviates materially' standard to assess the jury's verdict.

Held: New York's law controlling compensation awards for excessiveness or inadequacy can be given effect, without detriment to the Seventh Amendment, if the review standard set out in CPLR § 5501(c) is applied by the federal trial court judge, with appellate control of the trial court's ruling limited to review for 'abuse of discretion.'

Who won?

The prevailing party was the Center for Humanities, Inc., as the Supreme Court's decision effectively reduced the jury's award and required a new trial to reassess damages.

The Court of Appeals for the Second Circuit vacated the judgment entered on the jury's verdict. 66 F.3d 427 (1995).

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