Asa-Brandt, Inc. v. Farmers Co-Operative Society, No. C01-3021-MWB (N.D. Iowa 5/10/2002)
| Decision Date | 10 May 2002 |
| Docket Number | No. C01-3021-MWB.,C01-3021-MWB. |
| Parties | ASA-BRANDT, INC. a/k/a ASA-BRANDT PARTNERSHIP; PHILLIP ASA; KEITH BRANDT; ROBERT BECKER; DENNIS CINK; DUANE DEWAARD; BEVERLY EVERETT; RICHARD GARDNER; EDWARD A. OTIS; JIM OTIS; RONALD SCHMIDT; and DEBRA SCHMIDT, Plaintiffs, v. FARMERS CO-OPERATIVE SOCIETY, Defendant. |
| Court | U.S. District Court — Northern District of Iowa |
This matter came to trial on June 11, 2001, on plaintiffs' claims of breach of contract and breach of fiduciary duty against defendant Farmers Co-operative Society of Wesley ("Wesley"), and Wesley's counterclaims of breach of contract against each of the plaintiffs. On July 13, 2002, a jury returned a verdict in favor of each of the plaintiffs on their claims of breach-of-contract and breach of fiduciary duty with an award of damages and punitive damages, and against Wesley on its counterclaims of breach of contract.
On August 7, 2001, Wesley filed its Renewed Motion For Judgment As A Matter Of Law Pursuant To Rule 50(b) Or, Alternatively, For A New Trial Pursuant To Rule 59 (#146). In its motion, Wesley requests an order pursuant to Rule 50 of the Federal Rules of Civil Procedure granting it judgment as a matter of law on plaintiffs' breach of contract and breach of fiduciary duty claims on the ground that plaintiffs failed to produce sufficient evidence to support their claims or to support the award of punitive damages. Wesley also requests that the court grant it judgment as a matter of law on its breach of contract claims against plaintiffs. Alternatively, Wesley requests that the court grant it a new trial on all claims. Plaintiffs' filed a timely resistance to Wesley's post-trial motions.
This court set out the standards applicable to a post-trial motion for judgment as a matter of law in Mercer v. City of Cedar Rapids, 129 F. Supp.2d 1226 (N.D.Iowa 2001), as follows:
The standards for a motion for judgment as a matter of law are outlined in Rule 50 of the Federal Rules of Civil Procedure. In pertinent part, Rule 50 provides:
(a) Judgment as a Matter of Law.
(1) If during the trial by jury a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue, the court may determine the issue against that party and may grant a motion for judgment as a matter of law against that party with respect to a claim or defense that cannot under the controlling law be maintained or defeated without a favorable finding on that issue.
(2) Motions for judgment as a matter of law may be made at any time before the submission of the case to the jury. Such a motion shall specify the judgment sought and the law and the facts on which the moving party is entitled to the judgment.
(b) Renewing Motion for Judgment After Trial; Alternative Motion for New Trial. If, for any reason, the court does not grant a motion for judgment as a matter of law made at the close of all the evidence, the court is considered to have submitted the action to jury subject to the court's later deciding the legal questions raised by the motion. The movant may renew its request for judgment as a matter of law by filing a motion no later than 10 days after entry of judgment-and may alternatively request a new trial or join a motion for a new trial under Rule 59. In ruling on a renewed motion, the court may:
(1) if a verdict was returned:
(A) allow the judgment to stand,
(B) order a new trial, or
(C) direct entry of judgment as a matter of law;
or
(2) if no verdict was returned;
(A) order a new trial, or
(B) direct entry of judgment as a matter of law. FED R. CIV. P. 50(a)-(b).
The Eighth Circuit Court of Appeals reiterated the standards to be applied by the district court-as well as the appellate court-in determining a motion for judgment as a matter of law:
When the motion seeks judgment on the ground of insufficiency of the evidence, the question is a legal one. Hathaway v. Runyon, 132 F.3d 1214, 1220 (8th Cir. 1997); Jarvis v. Sauer Sundstrand Co., 116 F.3d 321, 324 (8th Cir. 1997). A jury verdict must be affirmed "`unless, viewing the evidence in the light most favorable to the prevailing party, we conclude that a reasonable jury could have not found for that party.'" Stockmen's Livestock Mkt., Inc. [v. Norwest Bank of Sioux City], 135 F.3d 1236, 1240-41 (8th Cir. 1998) (quoting Chicago Title Ins. Co. v. Resolution Trust Corp., 53 F.3d 899, 904 (8th Cir. 1995)).
Cross v. Cleaver, 142 F.3d 1059, 1066 (8th Cir. 1998); accord Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 120 S.Ct. 2097, 2109 147 L.Ed.2d 105 (2000) () (citations omitted). Thus, this standard requires the court to:
"[C]onsider the evidence in the light most favorable to the prevailing party, assume that the jury resolved all conflicts of evidence in favor of that party, assume as true all facts which the prevailing party's evidence tended to prove, give the prevailing party the benefit of all favorable inferences which may reasonably be drawn from the facts, and deny the motion, if in light of the foregoing, reasonable jurors could differ as to the conclusion that could be drawn from the evidence."
Minneapolis Community Dev. Agency v. Lake Calhoun Assoc., 928 F.2d 299, 301 (8th Cir. 1991) (quoting Atlas Pile Driving Co. v. DiCon Fin. Co., 886 F.2d 986, 989 (8th Cir. 1989)); see also Stephens v. Johnson, 83 F.3d 198, 200 (8th Cir. 1996) (citing Whitnack v. Douglas County, 16 F.3d 954, 956 (8th Cir. 1994), in turn, quoting Hasting v. Boston Mut. Life Ins. Co., 975 F.2d 506, 509 (8th Cir. 1992)); Haynes v. Bee-Line Trucking Co., 80 F.3d 1235, 1238 (8th Cir. 1996); Nelson v. Boatmen's Bancshares, Inc., 26 F.3d 796, 800 (8th Cir. 1994) (reiterating these factors, citing White v. Pence, 961 F.2d 776, 779 (8th Cir. 1992); McAnally v. Gildersleeve, 16 F.3d 1493, 1500 (8th Cir. 1994) (same).
This standard for consideration of a motion for judgment as a matter of law accords the jury's verdict substantial deference. Tilson v. Forrest City Police Dep't, 28 F.3d 802, 806 (8th Cir. 1994), cert. denied, 514 U.S. 1004, 115 S.Ct. 1315, 131 L.Ed.2d 196 (1995); McAnally, 16 F.3d at 1500. However, even with this deference to the jury's verdict, the jury cannot be accorded "the benefit of unreasonable inferences, or those `at war with the undisputed facts,'" McAnally, 16 F.3d at 1500 (quoting City of Omaha Employees Betterment Ass'n v. City of Omaha, 883 F.2d 650, 651 (8th Cir. 1989), in turn, quoting Marcoux v. Van Wyk, 572 F.2d 651, 653 (8th Cir.), cert. dismissed, 439 U.S. 801, 99 S.Ct. 43, 58 L.Ed.2d 94 (1978)), but the court must still defer to the jury's resolution of conflicting testimony. Jackson v. Virginia, 443 U.S. 307, 326, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979).
Mercer, 129 F. Supp.2d at 1230-32.
The standards cited in Mercer appear to be fully in accord with those stated in decisions of the Eighth Circuit Court of Appeals. See, e.g., Foster v. Time Warner Entertainment Co., 250 F.3d 1189, 1194 (8th Cir. 2001) () (internal quotation marks and citations omitted); Children's Broadcasting Corp. v. Walt Disney Co., 245 F.3d 1008, 1015 (8th Cir. 2001) (); Tatom v. Georgia-Pacific Corp., 228 F.3d 926, 931-32 (8th Cir. 2000) (); Belk v. City of Eldon, 228 F.3d 872, 877-78 (8th Cir. 2000) (), cert. denied, 121 S.Ct. 1734 (2001). Therefore, the court will apply these standards here.
Wesley contends that the jury's award of damages for Wesley's breach of contract is not supported by the evidence introduced at trial. Upon review of the record, the court concludes that sufficient evidence was presented at trial to support the jury's award of damages to plaintiffs for Wesley's breach of contract. Plaintiffs' damages theory was grounded on plaintiffs rolling their flex-hedge contracts to the next year or setting the basis for delivery under the flex-hedge contracts one week prior to the first notice day of the new crop futures contract. Plaintiffs' damages theory was fully supported by expert testimony. Plaintiffs' damages represent the difference in price between what plaintiffs could have sold their grain for under the flex-hedge contracts and what plaintiffs actually sold their grain for on the open market.
Wesley further argues that plaintiffs' breach of contract claim is barred by judicial estoppel. "The doctrine of judicial estoppel prohibits a party from taking inconsistent positions in the same or related litigation." Hossaini v. Western Mo. Med. Ctr., 140 F.3d 1140, 1142 (8th Cir. 1998) ...
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