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1. A district court is only overturned for failing to set aside a jury verdict if there is an “abuse of discretion.” 2. Questions of law are reviewed de novo by the appellate court.
A former manager filed a complaint against a musician alleging breach of contract for failure to pay royalties. The district court found that the musician had breached a modification agreement, awarded damages for failure to pay royalties on an album, and granted manager attorney's fees and costs. The district court denied musician’s post-judgment motions for relief. The musician appealed.
Did the district court abuse its discretion in failing to set aside the jury’s decision that appeared to be “against the weight of the evidence” presented at trial, and was the failure to pay royalties a violation of Massachusetts General Law Chapter 93A?
The appellate court found that the district court did not abuse its discretion by failing to set aside the jury verdict. In so finding, the court noted: “We remind appellant that under our standard of review, we do not sit as a juror, evaluating credibility and weighing evidence, as he seems to ask us to do. Rather, we simply weigh whether the district court committed a clear abuse of its discretion in determining that the jury verdict was not against the clear weight of the evidence."The district court’s findings of law were reviewed de novo, and the court held that the lower court erred in finding that 93A was violated. While circumstances surrounding the failure to pay were findings of fact within the district court’s discretion, the facts did not demonstrate the appropriate level of “rascality” required under the Massachusetts law.