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Henry Klein (Realigned as Plaintiff) Gur Shomron Amiram Grynberg Defendisk, Ltd., an Israeli Corporation v. Jack J. Grynberg, (Realigned as Defendant), and Defendisk, Inc., a Colorado Corporation Grynberg Petroleum Company, a Colorado Corporation

Citations: 127 F.3d 1109; 1997 U.S. App. LEXIS 34925; 1997 WL 643899Docket: 96-1255

Court: Court of Appeals for the Tenth Circuit; October 20, 1997; Federal Appellate Court

Narrative Opinion Summary

This case involves an appeal by the defendant against the district court's remittance of punitive damages following a directive from the Tenth Circuit in Klein v. Grynberg. Initially, the jury awarded $1.00 for breach of fiduciary duty and $3 million in punitive damages, which the district court struck down. The appellate court, however, found a significant punitive award necessary, leading the district court to reduce the punitive damages to $600,000 on remand. The defendant contended that this remittance violated his substantive and procedural due process rights and challenged the inclusion of interest from the original judgment date. The appellate court affirmed the remitted award and the decision to amend the mandate for interest. Additionally, the court denied motions for sanctions and other outstanding motions, emphasizing that the order and judgment lack binding precedent except under specific doctrines, though citation is allowed under certain conditions. This resolution underscores the appellate court's alignment with Supreme Court precedent regarding punitive damages and due process considerations.

Legal Issues Addressed

Due Process in Remittance of Damages

Application: Grynberg argued that the remittance of damages violated his substantive and procedural due process rights, but the appellate court found no such violation.

Reasoning: Grynberg argues this remittance violated his substantive and procedural due process rights, and disputes the amendment of the mandate to include interest from the original judgment date.

Interest on Amended Judgments

Application: The appellate court upheld the amendment of the mandate to include interest from the original judgment date, dismissing Grynberg's objections.

Reasoning: Grynberg argues this remittance violated his substantive and procedural due process rights, and disputes the amendment of the mandate to include interest from the original judgment date.

Non-Binding Nature of the Order and Judgment

Application: The order and judgment in this case do not serve as binding precedent, except under specific legal doctrines, but may be cited under certain conditions.

Reasoning: The order and judgment hold no binding precedent except under specific legal doctrines, though citation is permitted under certain conditions.

Remittance of Punitive Damages

Application: The district court reduced the punitive damages from $3 million to $600,000 upon remand, aligning with the appellate court's direction for a significant yet constitutionally acceptable award.

Reasoning: Upon remand, the district court reduced the punitive damages by 80% to $600,000, a figure deemed supported by the record and constitutionally acceptable under Supreme Court precedent.