Gasperini v. Center for Humanities, Inc.
United States Supreme Court
518 U.S. 415 (1996)
The Center (defendant) lost 300 of photojournalist Gasperini's (plaintiff) transparencies loaned for an educational video; after the Center conceded liability, a jury awarded Gasperini $450,000 in New York federal diversity court, based on expert testimony valuing each transparency at $1,500. The Center's motion for a new trial as excessive was denied by the district court, but the Second Circuit vacated the verdict under New York's CPLR Section 5501(c), which lets appellate courts order a new trial if an award "deviates materially from what would be reasonable compensation" — a more searching standard than the traditional federal "shocks the conscience" test — ordering a new trial unless Gasperini accepted a reduction to $100,000.
Whether a federal trial court sitting in diversity jurisdiction may apply a state-law standard for reviewing the excessiveness of a jury verdict, subject to appellate review only for abuse of discretion.