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Flying Fish Bikes, Inc. v. Giant Bicycle, Inc. - 181 F. Supp. 3d 957 (M.D. Fla. 2016)

Rule:

A claim of fraud sufficient to justify compensatory damages is also sufficient to support an award of punitive damages.

Facts:

Flying Fish Bikes, a retail distributor of bicycles, sued Giant Bicycle, a wholesale distributor of bicycles and Flying Fish's former supplier, for fraudulent misrepresentation. Flying Fish alleged that Giant fraudulently induced Flying Fish to purchase Giant bicycles by falsely promising that Giant would not supply any nearby competitor and by falsely promising that Giant would continue to supply Flying Fish. Flying Fish further alleged that Giant was simultaneously scheming with Outspokin, another bicycle retailer, to open a new store and to sell Giant bicycles in competition with Flying Fish — less than a mile-and-a-half from Flying Fish. Soon after Flying Fish's purchase of Giant bicycles, the Outspokin store opened and began selling Giant bicycles. Giant abruptly terminated Flying Fish despite it selling Giant bicycles for six years. A jury awarded Flying Fish $250,000 in compensatory damages and $3 million in punitive damages. Giant moved for a new trial or remittitur arguing (1) that Flying Fish did not establish that its lost profits were a direct result of Giant Bicycle's alleged misconduct or that the amount of those damages were determinable with reasonable certainty, (2) that the court erred in excluding evidence that substantially undermines credibility and plaintiff's lost profit claims and (3) that the jury's $3 million punitive damages award is arbitrary, excessive and does not comport with Florida or federal law.

Issue:

Should Giant's motion for new trial or remittitur be granted?

Answer:

No

Conclusion:

The Court held that the jury correctly found fraudulent misrepresentation and awarded compensatory damages because an award of punitive damages was an option available to the jury. The Court reiterated the rule that a claim of fraud sufficient to justify compensatory damages is also sufficient to support an award of punitive damages. It also held that the damages awarded were not excessive.

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