Johnston v. Castles & Crowns, Inc.

Summary

The Alabama Supreme Court considers whether the trial court erred by refusing to grant a new trial after the jury returned a verdict that was inconsistent with the court's instructions concerning conversion, conspiracy, and unjust enrichment. The court discusses Alabama principles requiring a new trial when a jury verdict is inconsistent or disregards the trial court's instructions. The opinion arises from a dispute over the shipment and resale of children's clothing inventory.

Holdings

1. When a jury returns a verdict that is inconsistent with the trial court's instructions, the trial court may not cure the inconsistency by selectively setting aside one part of the verdict after discharging the jury. The prejudiced party is entitled to a new trial because reconciling the verdict would require speculation about the jury's intent.
2. The new trial must encompass Castles's conversion, conspiracy, and unjust-enrichment claims against Johnston and Johnston's defamation and tortious-interference claims against Castles and Tibbetts.

Questions Presented

1. Whether the jury's verdict was inconsistent with the trial court's instructions when it found Johnston liable for unjust enrichment after finding her liable for conversion and conspiracy, and whether Johnston was therefore entitled to a new trial.
2. Whether the new trial should encompass the claims asserted by Castles against Johnston and Johnston's counterclaims and third-party claims against Castles and Tibbetts.

Disposition

reversed_and_remanded