Gasperini v. Center for Humanities
Encyclopedia
Gasperini v. Center for Humanities, 518 U.S. 415
(1996), was a decision by the Supreme Court of the United States
, in which the Court further refined the Erie doctrine
which regards when and how federal courts were to apply state
law
in cases brought under diversity jurisdiction
. The Court held that the New York State rule applied.
journalist
and photographer for CBS News
and the Christian Science Monitor who, during the course of seven years in Central America
, took over 5,000 slide transparencies depicting war, political leaders and everyday life. In 1990, Gasperini supplied 300
of his original transparencies to The Center for Humanities for use in an educational video. The center agreed to return the transparencies, but they were lost. Gasperini commenced suit in the United States District Court for the Southern District of New York
, invoking diversity jurisdiction
. The trial jury applied New York law and found for Gasperini, awarding him $450,000 in compensatory damages. The defendant moved for a new trial, asserting, among other things, excessiveness of the award. The district court dismissed the motion and the defendant appealed. The Second Circuit vacated and remanded for a new trial, unless the plaintiff accepted a remittitur
for $100,000. Gasperini petitioned and the Supreme Court granted certiorari
.
should be used by a federal court in measuring the excessiveness of a jury verdict. The standard typically applied by federal courts was that a verdict was excessive if it "shocked the conscience
of the court." New York
had recently enacted legislation changing the standard as a part of a tort reform
initiative, codifying in CPLR §5501(c) the standard that an award was excessive if it "deviates materially from what would be reasonable compensation." The question arose as to whether the standard was substantive or procedural, as the Erie Doctrine
stipulated that the federal court should apply the substantive law of the state and federal procedural law.
delivered the majority opinion of the Court, which held that the federal district court should apply the New York standard for excessiveness, reasoning that the case did not include a distinct choice between federal and state interests, but rather presented an opportunity to serve both interests. The federal interest lay primarily in discharging the Seventh Amendment
, which precludes review of facts tried by a jury. The Second Circuit had reviewed the verdict against the New York excessiveness standard and thus ran afoul of the Seventh Amendment. Accordingly, the Court vacated the judgment of the Second Circuit and ordered the case remanded to the district court for a new trial so that the trial judge could test the jury's verdict against the state standard.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1996), was a decision by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
, in which the Court further refined the Erie doctrine
Erie doctrine
In United States law, the Erie doctrine is a fundamental legal doctrine of civil procedure mandating that a federal court in diversity jurisdiction must apply state substantive law....
which regards when and how federal courts were to apply state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
law
Law
Law is a system of rules and guidelines which are enforced through social institutions to govern behavior, wherever possible. It shapes politics, economics and society in numerous ways and serves as a social mediator of relations between people. Contract law regulates everything from buying a bus...
in cases brought under diversity jurisdiction
Diversity jurisdiction
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction in civil procedure in which a United States district court has the power to hear a civil case where the persons that are parties are "diverse" in citizenship, which generally indicates that they are...
. The Court held that the New York State rule applied.
Background of the case
The plaintiff, William Gasperini, was an AmericanUnited States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
journalist
Journalist
A journalist collects and distributes news and other information. A journalist's work is referred to as journalism.A reporter is a type of journalist who researchs, writes, and reports on information to be presented in mass media, including print media , electronic media , and digital media A...
and photographer for CBS News
CBS News
CBS News is the news division of American television and radio network CBS. The current chairman is Jeff Fager who is also the executive producer of 60 Minutes, while the current president of CBS News is David Rhodes. CBS News' flagship program is the CBS Evening News, hosted by the network's main...
and the Christian Science Monitor who, during the course of seven years in Central America
Central America
Central America is the central geographic region of the Americas. It is the southernmost, isthmian portion of the North American continent, which connects with South America on the southeast. When considered part of the unified continental model, it is considered a subcontinent...
, took over 5,000 slide transparencies depicting war, political leaders and everyday life. In 1990, Gasperini supplied 300
300
Year 300 was a leap year starting on Monday of the Julian calendar. At the time, it was known as the Year of the Consulship of Constantius and Valerius...
of his original transparencies to The Center for Humanities for use in an educational video. The center agreed to return the transparencies, but they were lost. Gasperini commenced suit in the United States District Court for the Southern District of New York
United States District Court for the Southern District of New York
The United States District Court for the Southern District of New York is a federal district court. Appeals from the Southern District of New York are taken to the United States Court of Appeals for the Second Circuit The United States District Court for the Southern District of New York (in case...
, invoking diversity jurisdiction
Diversity jurisdiction
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction in civil procedure in which a United States district court has the power to hear a civil case where the persons that are parties are "diverse" in citizenship, which generally indicates that they are...
. The trial jury applied New York law and found for Gasperini, awarding him $450,000 in compensatory damages. The defendant moved for a new trial, asserting, among other things, excessiveness of the award. The district court dismissed the motion and the defendant appealed. The Second Circuit vacated and remanded for a new trial, unless the plaintiff accepted a remittitur
Remittitur
A remittitur is a ruling by a judge lowering the amount of damages granted by a jury in a civil case. Usually, this is because the amount awarded exceeded the amount demanded...
for $100,000. Gasperini petitioned and the Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Issue
The case involved an important issue of what standard of reviewStandard of review
In LAW, the standard of review is the amount of deference given by one court in reviewing a decision of a lower court or tribunal. A low standard of review means that the decision under review will be varied or overturned if the reviewing court considers there is any error at all in the lower...
should be used by a federal court in measuring the excessiveness of a jury verdict. The standard typically applied by federal courts was that a verdict was excessive if it "shocked the conscience
Conscience
Conscience is an aptitude, faculty, intuition or judgment of the intellect that distinguishes right from wrong. Moral judgement may derive from values or norms...
of the court." New York
New York
New York is a state in the Northeastern region of the United States. It is the nation's third most populous state. New York is bordered by New Jersey and Pennsylvania to the south, and by Connecticut, Massachusetts and Vermont to the east...
had recently enacted legislation changing the standard as a part of a tort reform
Tort reform
Tort reform refers to proposed changes in common law civil justice systems that would reduce tort litigation or damages. Tort actions are civil common law claims first created in the English commonwealth system as a non-legislative means for compensating wrongs and harm done by one party to...
initiative, codifying in CPLR §5501(c) the standard that an award was excessive if it "deviates materially from what would be reasonable compensation." The question arose as to whether the standard was substantive or procedural, as the Erie Doctrine
Erie doctrine
In United States law, the Erie doctrine is a fundamental legal doctrine of civil procedure mandating that a federal court in diversity jurisdiction must apply state substantive law....
stipulated that the federal court should apply the substantive law of the state and federal procedural law.
The court's decision
Justice GinsburgRuth Bader Ginsburg
Ruth Joan Bader Ginsburg is an Associate Justice of the Supreme Court of the United States. Ginsburg was appointed by President Bill Clinton and took the oath of office on August 10, 1993. She is the second female justice and the first Jewish female justice.She is generally viewed as belonging to...
delivered the majority opinion of the Court, which held that the federal district court should apply the New York standard for excessiveness, reasoning that the case did not include a distinct choice between federal and state interests, but rather presented an opportunity to serve both interests. The federal interest lay primarily in discharging the Seventh Amendment
Seventh Amendment to the United States Constitution
The Seventh Amendment to the United States Constitution, which was ratified as part of the Bill of Rights, codifies the right to a jury trial in certain civil cases. However, in some civil cases, the Supreme Court has not incorporated the right to a jury trial to the states in the fashion which...
, which precludes review of facts tried by a jury. The Second Circuit had reviewed the verdict against the New York excessiveness standard and thus ran afoul of the Seventh Amendment. Accordingly, the Court vacated the judgment of the Second Circuit and ordered the case remanded to the district court for a new trial so that the trial judge could test the jury's verdict against the state standard.