JP Morgan Chase Bank, N.A. v. Datatreasury Corp., No. 18-40043 (5th Cir. 2019)Annotate this Case
The Fifth Circuit affirmed the district court's denial of JMPC's motion to compel certain post-judgment discovery. The court held that, although the district court's reliance on the June 2011 date as relevant to DTC's knowledge of any potential claims by JPMC was clearly erroneous, the error was harmless. The court also held that the district court did not abuse its discretion by tying discovery to a time period associated with the Cathay agreement; the district court did not abuse its discretion by limiting discovery to the 2012 breach and the amount of the judgment specifically tied to that one breach; and the district court's proportionality determination was reasonable.