Summary
This memorandum opinion from the U.S. District Court for the Eastern District of Pennsylvania addresses post-trial motions filed by defendant MJ Freeway, LLC following a jury verdict in favor of plaintiff TreCom Systems Group, Inc. for breach of contract. The court denies the motion for judgment as a matter of law and new trial, finding sufficient evidence supported the jury’s determination that an Appendix N Subcontract governed the parties’ relationship and justified the $4.2 million damages award. The court also calculates and awards prejudgment and postjudgment interest according to Pennsylvania law and federal statute.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to support the jury’s finding that the Appendix N Subcontract governed the parties’ relationship.
- Whether the jury’s $4.2 million compensatory damages award was supported by the evidence.
- Whether prejudgment interest is available despite the limitation‑of‑liability provision.
- Whether the limitation‑of‑liability clause caps TreCom’s recovery at 35.09 % of MJ Freeway’s revenue.
Holdings
- The evidence was sufficient; the jury’s verdict is affirmed.
- The jury’s award is supported by the evidence and is affirmed.
- Prejudgment interest is available and awarded in the amount of $320,599.21.
- The limitation clause caps liability at 35.09 % of MJ Freeway’s revenue; it does not limit the amount of prejudgment interest.
Key quotations
“When a court directs a verdict, it must also decide whether a new trial is warranted.”
“Prejudgment interest under Pennsylvania law is available as a matter of right. If the Parties wanted to limit it, they needed to do so expressly.”
Factual background
TreCom and MJ Freeway entered a May 4, 2017 subcontract that was later superseded by an “Appendix N” subcontract. MJ Freeway terminated the May 4 subcontract in August 2020 and the parties performed under the Appendix N contract. At trial, the jury found that the Appendix N subcontract governed the relationship and awarded TreCom $4.2 million in damages.
Procedural history
The parties tried a six‑day jury trial. The jury returned a verdict for TreCom Systems Group, Inc. awarding $4.2 million in compensatory damages. MJ Freeway filed post‑trial motions for judgment as a matter of law and a new trial. The court denied the motions, entered judgment affirming the verdict, and awarded prejudgment and post‑judgment interest.