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Merry Gentleman, LLC v. George and Leona Productions, Inc.

United States Court of Appeals for the Seventh Circuit
799 F.3d 827 (2015)


Facts

Merry Gentleman, LLC (Merry Gentleman) (plaintiff) produced a movie called The Merry Gentleman. Michael Keaton (defendant) starred in and directed the movie. The movie was commercially unsuccessful but was shown at the Sundance Film Festival and critically acclaimed. Merry Gentleman brought suit against Keaton and Keaton’s professional contracting company, George and Leona Productions, Inc. (defendant). Merry Gentleman alleged that Keaton breached his contract by, among other things, failing to submit the movie’s first cut on time, submitting a second cut that was incomplete, and not adequately promoting the movie. Merry Gentleman claimed that Keaton’s breach caused the movie’s lack of commercial success. Merry Gentleman sought a return of the entire $5.5 million it spent producing the movie. In support, Merry Gentleman filed an affidavit stating that it spent over $5 million in reliance on the Keaton contract. Keaton filed a motion for summary judgment, arguing that even if he breached the contract, Merry Gentleman had not proved that the breach was the cause of any damages Merry Gentleman incurred. The trial court granted Keaton’s motion, finding that Merry Gentleman did not sufficiently prove causation. Merry Gentleman appealed.

Rule of Law

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Issue

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Holding and Reasoning (Hamilton, J.)

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