United Pool Distribution, Inc. v. Custom Courier Solutions, Inc.

Summary

The United States District Court for the Western District of New York resolves Defendant’s Rule 50 motion concerning Plaintiff’s entitlement to damages arising after expiration of a non-solicitation agreement. The Court permits Plaintiff to seek damages through August 2023 but precludes damages accruing after that date because the evidence of such damages was speculative and legally insufficient.

Holdings

1. Plaintiff was not precluded from seeking damages accruing between June 1, 2022 and August 2023 because it provided a legally sufficient evidentiary basis for a reasonable jury to find that reasonably certain damages actually followed from the breach.
2. Plaintiff was precluded from seeking damages accruing after August 2023 because it failed to provide a legally sufficient evidentiary basis for a reasonable jury to find that the fact of such damages was reasonably certain.
3. Judgment as a matter of law is appropriate when, after a full hearing on an issue at trial, there is no legally sufficient evidentiary basis for a reasonable jury to resolve the issue in favor of the nonmoving party.

Questions Presented

1. Whether Plaintiff presented a legally sufficient evidentiary basis for a reasonable jury to find reasonably certain breach-of-contract damages accruing between June 1, 2022 and August 2023.
2. Whether Plaintiff presented a legally sufficient evidentiary basis for a reasonable jury to find reasonably certain breach-of-contract damages accruing after August 2023.

Disposition

other