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Indianapolis Motor Speedway, LLC v. Karma International, LLC

United States District Court, S.D. Indiana, Indianapolis Division

October 26, 2018

INDIANAPOLIS MOTOR SPEEDWAY, LLC, Counterclaimant,
v.
KARMA INTERNATIONAL, LLC, Counterclaim Defendant.

          ENTRY ON POST-JUDGMENT MOTIONS AND BILL OF COSTS

          Hon. William T. Lawrence, Senior Judge

         This cause is before the Court on the Renewed Motion for Judgment as a Matter of Law under Federal Rule of Civil Procedure 50(b) or Alternatively for a New Trial on Counterclaim Plaintiff Indianapolis Motor Speedway, LLC's Counterclaim (Dkt. No. 109) filed by Counterclaim Defendant Karma International, LLC (“Karma”); Karma's Motion to Amend or Alter Judgment and for New Trial on Its Breach of Contract Claim (Dkt. No. 110). The Court, being duly advised, DENIES Karma's motions for the reasons set forth below. The Court also taxes costs in the amount of $7, 142.48.

         I. BACKGROUND

         This case arises out of an agreement between Plaintiff-Counterclaim Defendant Karma International, LLC, (“Karma”) and Defendant-Counterclaimant Indianapolis Motor Speedway, LLC, (“IMS”) pursuant to which Karma would host a party during the 2016 Indy 500 race weekend (hereinafter referred to as the “Maxim Party”). The Maxim Party would be marketed by both IMS and Karma and would use both the official Indy 500 brand and the Maxim brand. Each party alleged that the other did not fulfill its obligations under the agreement. The Court granted summary judgment in favor of IMS on Karma's claim because Karma failed to point to evidence from which a reasonable jury could find that it was damaged by any breach of the agreement by IMS. The case proceeded to a jury trial on IMS's counterclaim. The jury returned a verdict in favor of IMS in the amount of $75, 000.00. Judgment was entered accordingly.

         II. KARMA'S RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW (DKT. NO. 109)

         In Karma's Renewed Motion for Judgment as a Matter of Law, Karma timely renews the motion it made pursuant to Federal Rule of Civil Procedure 50 at the close of evidence at trial. “Judgment as a matter of law is proper if a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue.” Thorne v. Member Select Ins. Co., 882 F.3d 642, 644 (7th Cir. 2018) (citation omitted). In considering a Rule 50 motion, the Court must

construe the trial evidence strictly in favor of the party who prevailed before the jury. Although [the Court] must determine that more than a mere scintilla of evidence supports the verdict, [the Court does] not make credibility determinations or weigh the evidence. In other words, [the Court's] job is to decide whether a highly charitable assessment of the evidence supports the jury's verdict or if, instead, the jury was irrational to reach its conclusion.

Id. (citations and internal quotation marks omitted).

         Under Indiana law,

[t]he essential elements of a breach of contract action are the existence of a contract, the defendant's breach thereof, and damages. Generally, the measure of damages for breach of contract is either such damages as may fairly and reasonably be considered as arising naturally, i.e., according to the usual course of things from the breach of contract itself, or as may be reasonably supposed to have been within the contemplation of the parties at the time they entered into the contract as a probable result of the breach. A promisor is not required to compensate the injured party for injuries which, when the contract was made, the promisor had no reason to believe would be a probable result of the breach. The test for measuring damages is foreseeability at the time of entry into the contract, not facts existing and known to the parties at the time of the breach; the test is an objective one. Conversely, damages which do not arise naturally from the breach of contract, or which are not within the contemplation of the parties at the time the contract is entered into, are not recoverable.

Rogier v. American Testing & Eng'g Corp., 734 N.E.2d 606, 614 (Ind.Ct.App. 2000) (citations omitted) (emphasis added). Karma argues that “judgment must be entered as a matter of law in favor of Karma on IMS's breach of contract counterclaim as IMS failed to present any evidence at trial that IMS reasonably anticipated it would suffer damages if Karma failed to deliver to IMS a banner ad on Maxim.com or marketing support via Maxim social channels for IMS Music events.” Dkt. No. 109-2 at 6. However, given that the standard for foreseeability is an objective one, Karma is incorrect that IMS was required to offer evidence of what it actually anticipated with regard to potential damages at the time the agreement was reached. Rather, “[t]he issue of foreseeability of damages is generally to be determined by the trier of fact, ” and a party asserting a breach of contract claim is “entitled to present evidence of the breach and resulting damages and have the trier of fact determine what was reasonably foreseeable at the time of contracting.” WESCO Distribution, Inc. v. ArcelorMittal Indiana Harbor LLC, 23 N.E.3d 682, 710 (Ind.Ct.App. 2014). Karma does not argue that there was no evidence that IMS suffered damages; there clearly was, in the form of expert testimony. Karma also does not argue that the type of damages about which the expert testified could not “fairly and reasonably be considered as arising naturally, i.e., according to the usual course of things from the breach of contract itself.” See Rogier, 734 N.E.2d at 614. And, in any case, there was ample evidence at trial from which the jury reasonably could have concluded that the damages in question were reasonably foreseeable by the parties. See Dkt. No. 126 at 10-11 (citing to relevant trial testimony). Accordingly, Karma's Rule 50 motion is DENIED.

         Karma's motion also argues in the alternative that it is entitled to a new trial pursuant to Federal Rule of Civil Procedure 59(a) because the jury's verdict was against the weight of the evidence presented at trial. Rule 59(a)(1)(A) provides that a district court may order a new trial “for any reason for which a new trial has heretofore been granted in an action at law in federal court.” “[A] new trial is appropriate if the jury's verdict is against the manifest weight of the evidence or if the trial was in some way unfair to the moving party.” Martinez v. City of Chicago, 900 F.3d 838, 844 (7th Cir. 2018) (citation omitted).

When considering whether the jury's verdict goes against the manifest weight of the evidence, a court analyzes the general sense of the evidence, assessing the credibility of the witnesses and the comparative strength of the facts put forth at trial. But a verdict will be set aside as contrary to the manifest weight of the evidence only if no rational jury could have rendered the verdict. Moreover, jury verdicts deserve particular deference in cases with simple issues but highly disputed facts.

Willis v. Lepine, 687 F.3d 826, 836-37 (7th Cir. 2012) (citations and internal quotation marks omitted). For the reasons set forth below, Karma's Rule ...


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