Sony Electronics v. HannStar Display Corp., No. 14-15916 (9th Cir. 2016)
Annotate this CaseAfter Sony and HannStar engaged a mediator to resolve a price-fixing dispute, the mediator proposed settlement in an email exchange. Both parties accepted by email, but when HannStar refused to comply, Sony filed suit to enforce the agreement. The district court denied Sony’s motion for summary judgment, holding that the California Evidence Code’s mediation privilege bars introduction of the settlement emails. The parties stipulated to a final judgment. The court held that, because at the time the parties engaged in mediation, their negotiations concerned (and the mediated settlement settled) both federal and state law claims, the federal law of privilege applies. Accordingly, the court concluded that the district court erred in applying California privilege law to resolve this dispute. The court reversed and remanded.
Court Description: Law of Privilege. The panel reversed the district court’s order denying plaintiff’s motion for summary judgment in plaintiff’s action to enforce a settlement agreement, and remanded. The parties engaged a mediator to resolve a price-fixing dispute, and the mediator proposed settlement in an email exchange. Both parties accepted by email, but defendant refused to comply and plaintiff sued to enforce the settlement agreement. The district court denied plaintiff’s motion for summary judgment, holding that the California Evidence Code’s mediation privilege barred introduction of settlement emails. The parties stipulated to a final judgment. The panel held that because, at the time the parties engaged in mediation, their negotiations concerned (and the mediated agreement settled) both federal and state law IN RE: TFT-LCD (FLAT PANEL) ANTITRUST LITIG. 3 claims, the federal law of privilege applied. The panel therefore concluded that the district court erred in applying California privilege law to resolve the dispute. Dissenting, Chief District Judge Lynn would hold that the district court correctly determined that state privilege law governed and that California Evidence Code § 1123(b) precluded admission of the email exchange and the resulting settlement contract.
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