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Sargon Enterprises, Inc. v. University of Southern California

Citations: 215 Cal. App. 4th 1495; 156 Cal. Rptr. 3d 372; 2013 WL 1833016; 2013 Cal. App. LEXIS 352Docket: B202789

Court: California Court of Appeal; May 2, 2013; California; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In the litigation between a dental implant company (Sargon) and a university (USC), the core issue revolved around the exclusion of expert testimony on lost profits in a breach of contract case. Initially, Sargon was awarded $433,000 in compensatory damages, but the trial court excluded evidence of lost profits as too speculative. The appellate court initially reversed this exclusion, but the Supreme Court upheld it, finding the trial court acted within its discretion. Sargon argued that a new evidentiary standard warranted a retrial, but the court determined no new rule was established, thus affirming the exclusion as law of the case, preventing further action on lost profit damages. The stipulated judgment, aimed at expediting appeal, precluded Sargon from introducing new theories of damages. Consequently, the court affirmed the trial court's judgment and dismissed USC's cross-appeal, with both parties bearing their own appeal costs. The case emphasizes the doctrine of law of the case and the retroactive application of Supreme Court rulings.

Legal Issues Addressed

Exclusion of Expert Testimony on Lost Profits

Application: The trial court acted within its discretion to exclude expert testimony on lost profits due to its speculative nature and lack of reliable foundations.

Reasoning: The Supreme Court concluded that the trial court acted within its discretion in excluding Sargon's lost profit expert testimony.

Law of the Case Doctrine

Application: The appellate court's decision on the exclusion of expert testimony became binding, preventing further litigation on that issue.

Reasoning: The court finds that Sargon’s claim of a 'new rule' is misplaced, asserting that the Supreme Court's decision addressed the merits of the trial court's exclusion of expert testimony, thus establishing it as law of the case.

New Trial Motions After Appeal

Application: New trial motions cannot be granted once an appeal has been taken and ruled upon.

Reasoning: New trial motions are limited to trial court proceedings and do not apply once an appeal has been taken and ruled upon.

Retroactivity of Supreme Court Decisions

Application: Supreme Court decisions apply retroactively unless they establish a new rule of law, which in this case, it did not.

Reasoning: It reiterates the principle that Supreme Court decisions generally hold retroactive effect unless they alter a settled rule relied upon by the parties.

Stipulated Judgment and Res Judicata

Application: The stipulated judgment barred subsequent actions on the same cause, functioning like a final judgment after trial.

Reasoning: The stipulated judgment is conclusive on issues it addresses, functioning like a final judgment after trial, and does not reserve issues for further litigation.