Drakeford v. Capital Benefit, Inc.

CourtDistrict Court, N.D. California
DecidedJuly 8, 2022
Docket3:20-cv-04161
StatusUnknown

This text of Drakeford v. Capital Benefit, Inc. (Drakeford v. Capital Benefit, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Drakeford v. Capital Benefit, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RHONDA DRAKEFORD, et al., Case No. 20-cv-04161-WHO

8 Plaintiffs, ORDER ON POST-TRIAL MOTIONS 9 v. AND JUDGMENT

10 CAPITAL BENEFIT, INC., et al., Re: Dkt. Nos. 136, 146 Defendants. 11

12 Defendants’ renewed motion for judgment as a matter of law or, in the alternative for a 13 new trial, is DENIED. The jury had more than sufficient evidence to support their verdict. And in 14 light of that evidence and verdict, plaintiffs’ motion for relief under California’s Unfair 15 Competition Law (“UCL”) is GRANTED. 16 BACKGROUND 17 On March 28, 2022, the jury returned its verdict in this case, concluding that the loan 18 plaintiffs’ Rhonda and Reginald Drakeford secured from defendants was primarily for consumer 19 purposes and that it and defendants violated the Federal Truth in Lending Act, the Real Estate 20 Settlement Procedures Act and the Rosenthal Fair Debt Collection Practices Act. Dkt. No. 133. 21 The jury also determined that the Drakefords were not “sophisticated borrowers who took 22 deliberate and calculated steps to mislead defendants into believing the loan at issue was being 23 obtained” for business purposes. Id. 24 The jury also found that defendants Marcel Bruetsch and Capital Benefit, Inc. breached the 25 fiduciary duties that they owed to the Drakefords and that the breach was a substantial factor in 26 causing harm to the Drakefords. Id. The jury awarded statutory but not actual damages to the 27 Drakefords on their statutory claims and $13,791.94 in damages for the breach of fiduciary duties. 1 required for punitive damages), but that Bruetsch and Capital Benefit, Inc. acted with unclean 2 hands. Id. 3 On the defendants’ counterclaim, the jury found that the Drakefords did not make 4 fraudulent misstatements or fraudulently conceal material information but did negligently make 5 misrepresentations to defendants. However, the jury awarded no damages to defendants for those 6 negligent misrepresentations and expressly concluded that the Drakefords did not act with malice, 7 fraud, oppression, or with unclean hands. Id. 8 Defendants now move for judgment notwithstanding the verdict, contending that all of the 9 Drakefords’ claims are barred by the doctrine of equitable estoppel, that if the Drakefords are 10 entitled to any relief it is only rescission of the loan under TILA, and that the defendants should 11 otherwise be considered the “prevailing parties.” Dkt. No. 136. Plaintiffs have also moved for 12 entry of findings of fact and conclusions of law on the California Unfair Competition claim 13 (“UCL,” Cal. Bus. & Prof. Code 17200 et seq.,), which was tried to the court, as well as entry of 14 their proposed form of judgment. Dkt. No. 146. 15 DISCUSSION 16 I. DEFENDANTS’ RENEWED MOTION FOR JUDGMENT AND REQUEST FOR A NEW TRIAL 17 Defendants move to set aside the jury’s verdict, arguing that the Drakefords failed to 18 introduce sufficient evidence at trial to support their statutory or breach of fiduciary duty claims 19 and that, regardless, any recovery under those claims is barred by equitable estoppel. 20 A. Legal Standards 21 Federal Rule of Civil Procedure (“FRCP”) 50 governs judgments as a matter of law 22 (“JMOL”) in jury trials. Under Rule 50(a)(1), “[i]f a party has been fully heard on an issue during 23 a jury trial and the court finds that a reasonable jury would not have a legally sufficient evidentiary 24 basis to find for the party on that issue, the court may: (A) resolve the issue against the party; and 25 (B) grant a motion for judgment as a matter of law against the party on a claim or defense that, 26 under the controlling law, can be maintained or defeated only with a favorable finding on that 27 issue.” If a party files a motion under Rule 50(a) that the court does not grant, Rule 50(b) provides 1 that “the movant may file a renewed motion for judgment as a matter of law and may include an 2 alternative or joint request for a new trial under Rule 59.” The court may then (1) allow judgment 3 on the verdict, (2) order a new trial, or (3) enter judgment as a matter of law. Fed. R. Civ. P. 4 50(b)(1)–(3). 5 A motion for JMOL can only be granted if “the court finds that a reasonable jury would 6 not have a legally sufficient evidentiary basis to find for the party” against whom the motion is 7 brought. Fed. R. Civ. P. 50(a). In other words, to grant the motion, “under the governing law, 8 there can be but one reasonable conclusion as to the verdict.” Shafer v. Cnty. of Santa Barbara, 9 868 F.3d 1110, 1115 (9th Cir. 2017) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250 10 (1986)) (internal quotation marks omitted). The court must “construe the facts in the light most 11 favorable to the jury’s verdict.” Id. (internal quotation marks and citations omitted). “A jury’s 12 verdict must be upheld if it is supported by substantial evidence, which is evidence adequate to 13 support the jury’s conclusion, even if it is also possible to draw a contrary conclusion.” Pavao v. 14 Pagay, 307 F.3d 915, 918 (9th Cir. 2002). When examining the record, “the court must not weigh 15 the evidence, but should simply ask whether the plaintiff has presented sufficient evidence to 16 support the jury’s conclusion.” Harper v. City of Los Angeles, 533 F.3d 1010, 1021 (9th Cir. 17 2008). Consequently, the court “is not to make credibility determinations” and “must accept the 18 jury’s credibility findings consistent with the verdict. It must disregard all evidence favorable to 19 the moving party that the jury is not required to believe.” Winarto v. Toshiba Am. Elecs. 20 Components, Inc., 274 F.3d 1276, 1283 (9th Cir. 2001) (internal quotation marks and citations 21 omitted). 22 FRCP 59 governs motions for a new trial. A court may grant a new trial “on all or some of 23 the issues . . . after a jury trial, for any reason for which a new trial has heretofore been granted in 24 an action at law in federal court.” Fed. R. Civ. P. 59(a)(1). “The authority to grant a new trial . . . 25 is confided almost entirely to the exercise of discretion on the part of the trial court.” Allied Chem. 26 Corp. v. Daiflon, Inc., 449 U.S. 33, 36 (1980). “[E]ven if substantial evidence supports the jury’s 27 verdict, a trial court may grant a new trial if the verdict is contrary to the clear weight of the 1 trial court, a miscarriage of justice.” Silver Sage Partners, Ltd. v. City of Desert Hot Springs, 251 2 F.3d 814, 819 (9th Cir. 2001) (internal quotation marks and citation omitted). Likewise, a new 3 trial is warranted when “it is quite clear that the jury has reached a seriously erroneous result.” 4 Oracle Corp. v. SAP AG, 765 F.3d 1081, 1093 (9th Cir. 2014).

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