691 F.3d 972
8th Cir.2012Background
- Vaidyanathan sued Seagate US LLC and Seagate Technology LLC in Minnesota statute claim and promissory estoppel in state court, later removed to federal court.
- Statutory claim (Minn. Stat. § 181.64) alleges knowingly false representations about the kind or character of the job induced relocation and employment.
- Jury found in Vaidyanathan’s favor on the statutory claim and awarded $1.9 million; district court entered judgment, awarded fees, and dismissed the promissory estoppel claim with prejudice.
- Evidence showed Vaidyanathan was told he would serve as a yield engineer in Seagate’s R&D, but upon arrival the role and technology were not as described.
- Seagate argued the jury instruction defining “knowingly false representations” was erroneous; Seagate sought a new trial and Vaidyanathan cross-appealed for retrial of promissory estoppel if a new trial was granted.
- The court vacated the judgment on the statutory claim, remanded for a new trial on both claims, and vacated fee award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the jury instruction on knowingly false representations misstated Minnesota law | Vaidyanathan argues instruction misdefined knowledge of falsity. | Seagate contends instruction conformed to applicable law and Minnesota standard. | Instruction incorrect; reversal and new trial on both claims. |
| Whether the promissory estoppel claim should be retried if a new trial is ordered | Vaidyanathan seeks retrial of promissory estoppel if statutory claim is retried. | Seagate disputes retrial of promissory estoppel upon remand. | Remand to allow new trial on promissory estoppel with statutory claim. |
Key Cases Cited
- Davis v. Re-Trac Mfg. Corp., 276 Minn. 116 (Minn. 1967) (knowledgeable false representations require knowing falsity)
- Menkevich v. Lefebvre, 303 N.W.2d 462 (Minn. 1981) (definition of knowingly false representations)
- Bank v. Egan, 240 Minn. 192 (Minn. 1953) (interpretation of knowingly under statute)
- Linden v. CNH Am., LLC, 673 F.3d 829 (8th Cir. 2012) (standard for reviewing jury instructions in diversity cases)
- McCoy v. Augusta Fiberglass Coatings, Inc., 593 F.3d 737 (8th Cir. 2010) (statutory interpretation and jury instruction considerations)
- Brayton v. Pawlenty, 781 N.W.2d 357 (Minn. 2010) (statutory interpretation approach in Minnesota)
- Am. Tower, L.P. v. City of Grant, 636 N.W.2d 309 (Minn. 2001) (plain meaning rule and statutory construction principles)
- Kratzer v. Welsh Cos., 771 N.W.2d 14 (Minn. 2009) (no specialized meaning for general terms absent ambiguity)
- Slidell, Inc. v. Millennium Inorganic Chems., Inc., 460 F.3d 1047 (8th Cir. 2006) (new trial standards and effect of instructional error)