Court: District Court of Appeal of Florida; April 1, 2004; Florida; State Appellate Court
Armand Rivard, Lake Aircraft, Inc., Ae-rofab, Inc., and Revo, Inc. (collectively referred to as Lake Aircraft) appeal a final judgment favoring G. Leonard Gioia, M.D., and Archedyne Aerospace Corp. (collectively Archedyne) following a jury verdict. Lake Aircraft argues that the jury's verdict was against the manifest weight of the evidence, that the awarded damages were excessive, and that the jury lacked adequate time to evaluate the evidence. Archedyne cross-appeals the denial of its motion to amend its complaint to include punitive damages.
The litigation stemmed from an "Option Offer to Purchase Certain Assets of the Lake Aircraft Group of Companies," where Archedyne had deposited $500,000. The primary issue centered on the return of this deposit, with Archedyne stipulating not to claim incidental or consequential damages exceeding that amount. During trial, Dr. Gioia was questioned about his expenditures related to developing an amphibian jet aircraft, which he estimated between $1 million and $1.25 million based on Lake Aircraft's counsel's figure. Despite this, Dr. Gioia did not present evidence of damages beyond the $500,000 deposit, and the jury awarded $1.25 million.
Lake Aircraft's motions for judgment notwithstanding the verdict, remittitur, or a new trial were denied. The court identified that a jury cannot award damages exceeding what is supported by trial evidence. As the evidence supported a maximum refund of the $500,000 deposit, the trial court abused its discretion by denying remittitur. The ruling is reversed and remanded, instructing the trial court to offer Archedyne the option to accept a reduced verdict of $500,000. If Archedyne declines, a new trial on damages will be ordered. The court found no error in the remaining issues raised. The decision concludes with a reversal and remand, with Judges Palmer and Orfinger concurring.
