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Game Tech International v. Trend Gaming, LLC

Citation: 223 F. App'x 736Docket: No. 04-17087

Court: Court of Appeals for the Ninth Circuit; March 4, 2007; Federal Appellate Court

Narrative Opinion Summary

In this case, Trend Gaming and the Hieronymus defendants appealed several district court decisions, including the denial of their summary judgment motion and judgment as a matter of law on punitive damages, as well as issues related to jury instructions and damages awards. The central legal issues involved the interpretation of a restrictive covenant and the appropriateness of punitive damages. The district court's denial of the summary judgment was affirmed due to the presence of genuine issues of material fact about the contract's intent, necessitating a de novo review. The jury's decision on the reasonableness of the restrictive covenant, although typically a legal question, was upheld as fact-intensive under Arizona law. The refusal to grant a new trial was also affirmed, with the court finding sufficient evidence to support the jury's verdict on damages, favoring testimony that contradicted Mr. Hieronymus’s assertions. Furthermore, the denial of Trend's motion regarding punitive damages was sustained, as the jury's verdict of malice was supported by adequate evidence. The appellate court concluded that any alleged errors were harmless, thereby affirming the district court's judgments and rulings in favor of GameTech International.

Legal Issues Addressed

Denial of Summary Judgment under De Novo Review

Application: The district court's denial of the summary judgment motion was upheld because genuine issues of material fact regarding intent made the contract susceptible to multiple interpretations.

Reasoning: The district court's denial of the summary judgment motion was upheld because genuine issues of material fact regarding intent made the contract susceptible to multiple interpretations, which is a legal question reviewed de novo.

Judgment as a Matter of Law on Punitive Damages

Application: The court denied Trend's renewed motion for judgment as a matter of law concerning punitive damages, as there was sufficient evidence to support the jury's finding of malice.

Reasoning: The jury's finding that Trend and Hieronymus acted with malice in interfering with GameTech’s business relationships was supported by adequate evidence, making the punitive damages award reasonable.

Motion for a New Trial and Abuse of Discretion Standard

Application: The district court's decision to deny a motion for a new trial was affirmed based on the sufficiency of evidence supporting the jury's verdict, applying the abuse of discretion standard.

Reasoning: A motion for a new trial is reviewed for abuse of discretion, with reversal occurring only if the district court legally errs in applying the standard or if the record lacks supporting evidence for the verdict.

Reasonableness of Restrictive Covenant under Arizona Law

Application: The reasonableness of the restrictive covenant was submitted to the jury, with the court finding no error in this decision due to its fact-intensive nature under Arizona law.

Reasoning: The submission of the restrictive covenant's reasonableness to the jury was not deemed erroneous, as it is generally a legal question, although fact-intensive under Arizona law.