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Maria Teresa De Saracho,eureka Canners Group, S.A., a Corporation Formed Under the Laws of Mexico Eureka Mexicana Sa,a Corporation Formed Under the Law of Mexico,plaintiffs-Appellees v. Custom Food MacHinery Inc., a California Corporation Ron McNeil Sr., and Fred Avalli, and Doe 1 Through Doe 25, Inclusive

Citation: 206 F.3d 874Docket: 98-15003

Court: Court of Appeals for the Ninth Circuit; March 2, 2000; Federal Appellate Court

Narrative Opinion Summary

In the case involving allegations of fraud and breach of fiduciary duty, the Ninth Circuit Court reviewed several post-trial motions following a jury verdict awarding $12.5 million to the plaintiffs, who suffered business losses due to alleged misrepresentations by the defendants. The defendants, including a machinery company and its president, appealed the denial of motions to dismiss a plaintiff, strike expert testimony, request a new trial, and seek relief from judgment under Rule 60(b)(3). The district court's denial of these motions was affirmed, as the appellate court found no abuse of discretion. The defendants' challenge to the plaintiffs' authority to sue was dismissed as untimely. The court also upheld the admissibility of expert testimony on financial liability, finding no error in the district court's discretion. The plaintiffs successfully demonstrated the financial impact and legal validity of their claims under Mexican law, which the defendants failed to rebut effectively. Circuit Judge Bright dissented, objecting to the acceptance of allegedly erroneous expert testimony, and suggested a reduction in the damages award. Ultimately, the appellate court upheld the district court's rulings, maintaining the jury's verdict in favor of the plaintiffs.

Legal Issues Addressed

Admissibility of Expert Testimony

Application: The district court admitted the expert testimony of CPA Stephan Degnan regarding the calculation of default interest rates, overriding objections about the reliability of the underlying documents.

Reasoning: The court's decision to admit this testimony is reviewed for abuse of discretion, and since defendants did not challenge Degnan’s qualifications or assumptions during the trial, they cannot raise these issues on appeal.

Denial of Motion to Dismiss Plaintiff

Application: The court affirmed the denial of defendants' motion to dismiss one plaintiff due to the untimeliness of raising the issue regarding the authority to sue.

Reasoning: Even if reviewed, the court agreed that defendants waived their objection to plaintiffs' authority to sue by not raising it in their initial pleadings or motions, as required by case law.

Motion for New Trial

Application: The motion for a new trial was denied, with the court finding that sufficient evidence supported the jury's damage awards and that there was no abuse of discretion.

Reasoning: Defendants also contend that a new trial is warranted under Rule 59 due to insufficient evidence supporting the jury's damage awards. However, they did not demonstrate inaccuracies in Degnan’s assessment of liability.

Rule 60(b)(3) Relief from Judgment

Application: The defendants' motion for relief from judgment under Rule 60(b)(3) was denied due to lack of evidence of plaintiffs' misconduct or unjust acquisition of the judgment.

Reasoning: The district court rejected this motion, finding no misconduct by the plaintiffs and that the judgment was not unjustly obtained.

Subject Matter Jurisdiction

Application: The appellate court confirmed that the subject matter jurisdiction remained intact irrespective of the ECG's authority to sue.

Reasoning: Subject matter jurisdiction of the court remains intact even if ECG lacked authorization to sue, as the capacity to sue does not impact jurisdiction.