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Gasperini v. Center for Humanities, Inc.

United States Supreme Court
518 U.S. 415 (1996)

Gasperini v. Center for Humanities, Inc.

Facts

Photojournalist William Gasperini (plaintiff) amassed a collection of photographs from his work in Central America. The Center for Humanities, Inc. (Center) (defendant) asked to use some of Gasperini's images in an educational video. Gasperini loaned the Center 300 transparencies, which were lost. Gasperini sued the Center in the United States District Court for the Southern District of New York under diversity jurisdiction. The Center conceded liability, and the only issue for trial was damages. Gasperini’s expert witness testified that the industry standard value was $1,500 per transparency. The jury awarded Gasperini $450,000, and the Center moved for a new trial, arguing that the award was excessive. The district court denied the motion, and the Center appealed. New York state law gives appellate courts the authority to order a new trial if a jury damage award “deviates materially from what would be reasonable compensation.” N.Y. C.P.L.R. (CPLR) § 5501(c). The court of appeals vacated the judgment pursuant to CPLR § 5501(c), finding that the verdict materially deviated from reasonable compensation. The appellate court ordered a new trial unless Gasperini agreed to reduction of the award to $100,000. The United States Supreme Court granted certiorari to review.

Rule of Law

Issue

Holding and Reasoning (Ginsburg, J.)

Dissent (Scalia, J.)

Dissent (Stevens, J.)

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