Adeli v. Silverstar Automotive, No. 19-1481 (8th Cir. 2020)
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Plaintiff filed suit against Silverstar, alleging that it intentionally misrepresented the condition of the used Ferrari it sold him. A jury awarded plaintiff $20,201 in compensatory and incidental damages and $5.8 million in punitive damages on his claims for fraud, breach of express warranty, and deceptive trade practices under Arkansas law. The district court subsequently denied Silverstar's renewed motion for judgment as a matter of law but partially granted its motion to alter or amend the judgment, reducing the jury's punitive damages award to $500,000.
The Eighth Circuit affirmed, holding that the evidence was sufficient to establish justifiable reliance on Silverstar's misrepresentations about the conditions of the car; the district court did not err in denying Silverstar's renewed motion for judgment as a matter of law on plaintiff's fraud claim where an "as is" clause does not bar an action by the vendee based on claims of fraud or misrepresentation; and the court need not address whether Silverstar should have been granted judgment as a matter of law on plaintiff's other claims for breach of warranty and deceptive trade practices, because Arkansas law allows a successful fraud plaintiff to recover compensatory, incidental, and punitive damages. The court also held that the district court did not err in reducing the punitive damages award, because the award was grossly excessive and in violation of the due process clause.
Court Description: [Grasz, Author, with Benton and Stras, Circuit Judges] Civil case - Fraud. The evidence was sufficient to establish plaintiff's justifiable reliance on defendant's misrepresentations concerning the condition of the 2007 Ferrari F430 plaintiff purchased from defendant; under Arkansas law, an "as is" clause in the purchase documents does not bar an action for fraud or misrepresentation; the jury did not err in awarding punitive damages as there was evidence to support a finding the defendant's conduct was reprehensible; the district court did not err in reducing the jury's $5.8 million punitive damage award to $500,000 as the jury award was grossly excessive, in violation of the Due Process Clause. Judge Stras, concurring.
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