Regions Bank v. Griffin, 364 Ark. 193

Summary

The Arkansas Supreme Court affirmed the denial of Regions Bank's motion for a new trial concerning the jury's $10 fraud-damages award against Todd Griffin. The court held that awarding the bank the additional $2,608,216.12 sought for fraud would result in an impermissible double recovery because the jury had already awarded $2,600,000 for breach of contract arising from the same injury. The court also left undisturbed the $10 fraud award because Griffin had not cross-appealed.

Holdings

1. Under Arkansas's election-of-remedies doctrine, a plaintiff may pursue multiple theories of recovery, but may not obtain more than one recovery for the same injury. The jury therefore should have been instructed to choose between the contract and fraud remedies rather than award damages under both theories.
2. The denial of the motion for new trial was affirmed because the appellate court will affirm a correct result even when the trial court reached it for the wrong reason.

Questions Presented

1. Whether the circuit court abused its discretion by denying Regions Bank's motion for a new trial based on the allegedly inadequate $10 fraud damages award.
2. Whether Regions Bank could recover the same approximately $2.6 million injury under both its breach-of-contract and fraud theories.

Disposition

affirmed