Gaia Technologies Inc. v. Recycled Products Corp.’s Empirical Analysis

Citation profile

15 federal appellate ·

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Nothing in the text of Rule 49(a) authorizes a district court to reform a jury’s decision on issues submitted to the jury. Rule 49(a) allows the district court to make its own findings only as to issues not submitted to the jury ... Furthermore, Rule 49(a) does not permit a district court to make findings contrary to the jury verdict. See Askanase [v. Fatjo ], 130 F.3d [657] at 670 [ (5th Cir.1997) ] (‘Appellant correctly states that a Rule 49(a) finding cannot be inconsistent with the jury verdict.’); see also Floyd v. Laws, 929 F.2d 1390, 1397 (9th Cir.1991) (holding that ‘under Rule 49(a), the trial court simply cannot choose to ignore a legitimate finding that is part of the special verdict’). Here, the district court submitted the elements of Gaia’s state law claims to the jury, and the jury found that Gaia failed to prove any of the elements as to the individual defendants. Thus Rule 49(a) does not authorize the district court to reform the jury’s state law findings in order to hold the individual defendant’s liable for Gaia’s state law causes of action.”

   1 later decision quote this exact passage · from the majority
   e.g. 758 F. Supp. 2d 1004 - Flagship West, LLC v. Excel Realty Partners, L.P.

2. “Preliminarily, the individual defendants contend that we should treat the jury verdict as a general verdict accompanied by interrogatories, governed by Rule 49(b), as opposed to a special verdict, governed by Rule 49(a) ... According to the defendants, Rule 49(b) affords greater deference to a jury’s finding than Rule 49(a). We need not address this contention, however, because we conclude that not even Rule 49(a) authorizes the district court’s modification of the jury verdict. Gaia does not contend that Rule 49(b) provides an alternative ground for upholding the district court’s reformation.”

   1 later decision quote this exact passage · from the majority
   e.g. 758 F. Supp. 2d 1004 - Flagship West, LLC v. Excel Realty Partners, L.P.

3. “Under Boeing, there must be a conflict in substantial evidence to create a jury question. Substantial evidence is defined as evidence of such quality and weight that reasonable and fair-minded men in the exercise of impartial judgment might reach different conclusions. Consequently, a mere scintilla of evidence is insufficient to present a question for the jury. Even if the evidence is more than a scintilla, Boeing assumes that some evidence may exist to support a position which is yet so overwhelmed by contrary proof as to yield to a [motion for judgment as a matter of law]. 51”

   1 later decision quote this exact passage · from the majority
   e.g. Rogers v. McDorman