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Law School Case Brief

Trivedi v. Cooper - 95 Civ. 2075 (DLC), 1996 U.S. Dist. LEXIS 18715 (S.D.N.Y. Dec. 16, 1996)

Rule:

A motion for judgment as a matter of law should be granted when (1) there is such a complete absence of evidence supporting the verdict that the jury's findings could only have been the result of sheer surmise and conjecture, or (2) there is such an overwhelming amount of evidence in favor of the movant that reasonable and fair-minded persons could not arrive at a verdict against it. 

Facts:

While Plaintiff Vipin Trivedi, a person of East Asian Indian origin, worked as a research scientist for a state office, he claimed that his supervisor, defendant Thomas Cooper, subjected him to disparaging racial remarks, failed to promote him, and caused him to perform menial labor. After Trivedi brought an employment discrimination action against Cooper and the state office, the state office was dismissed, and Trivedi obtained a verdict of $700,000 against Cooper. Cooper filed timely motions for judgment as a matter of law, for a new trial, or for a remittitur. 

Issue:

Should the motion for a judgment as a matter of law be granted?

Answer:

No

Conclusion:

The federal district court denied the motion for a judgment as a matter of law because the jury was justified in rendering a verdict for Trivedi, the verdict was not based on sheer surmise and conjecture, nor could a reasonable and fair-minded person not have found for rivedi. Although a new trial was not warranted under Fed. R. Civ. P. 59, a remittitur was warranted because the award for emotional damages was excessive in light of similar cases and the evidence underlying the award. Trivedi had to choose between a new trial as an alternative to remittitur because damages could not have been separated from liability.

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