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Gasperini v. Center for Humanities, Inc.

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


Facts

Journalist William Gasperini (plaintiff) reported from Central America. The Center for Humanities, Inc. (Center) (defendant) asked to borrow slide transparencies Gasperini took. Gasperini lent the Center 300 transparencies, which were lost. Gasperini sued 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 under Federal Rule of Civil Procedure (FRCP) 59, arguing that the award was excessive. The district court denied the motion without comment, 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 court of appeals ordered a new trial unless Gasperini agreed to reduction to $100,000. Gasperini petitioned the United States Supreme Court for certiorari, which was granted.

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Holding and Reasoning (Ginsburg, J.)

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Dissent (Stevens, J.)

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