Quimbee logo
DMCA.com Protection Status
From our private database of 16,500+ case briefs...

Hoffman v. L & M Arts Health System, Inc.

United States Court of Appeals, Fifth Circuit
838 F.3d 568 (2016)


Facts

Marguerite Hoffman (plaintiff) owned a valuable painting, referred to as the Red Rothko, that she wanted to sell. However, for a variety of reasons, news of the sale could hurt Hoffman’s reputation. Accordingly, Hoffman wished to sell the painting in a secret, private sale. Hoffman engaged L & M Arts Health System, Inc. (L&M) (defendant) to help sell the painting on these terms. L&M found a buyer, David Martinez (defendant). The parties ultimately entered a sale agreement for $17.6 million, with a confidentiality clause in the agreement. Several years later, Martinez decided to sell the Red Rothko. Hoffman offered to buy back the painting, but Martinez declined her offer. Instead, Martinez sold the Red Rothko at a very public auction for approximately $31 million. Hoffman sued Martinez and L&M in Texas state court for breaching the confidentiality clause in the original sale contract, and the defendants removed the case to federal district court. The parties disputed the meaning of the confidentiality clause, with the existence of a breach turning on the interpretation. The district court found that there was a breach, and a jury awarded Hoffman the difference between the amount that Hoffman would have received for a public sale (without any confidentiality) and the $17.6 million that Hoffman received for the private sale (with the confidentiality clause). The defendants appealed both the breach finding and the validity of the measurement of damages. On appeal, Hoffman sought either affirmation of the current award or else restitution damages in the form of Martinez disgorging the amount he was enriched by the public-auction sale in violation of the confidentiality clause.

Rule of Law

Issue

Holding and Reasoning (Elrod, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 409,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,500 briefs, keyed to 223 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers


Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial