Input/Output Marine Systems, Inc. v. Wilson Greatbatch, Technologies, Inc.
52 So. 3d 909
La. Ct. App.2010Background
- Input/Output and IO Marine sued Wilson Greatbatch entities alleging misappropriation of trade secrets for a marine battery used in seismic work.
- Jury verdict on Oct. 1, 2009 found fraud and LUTPA liability with specific damages totaling $15,733,411 and $6,000,000; breach of contract damages of $2,500,000 were also found.
- On Oct. 5, 2009 the trial judge signed a purported judgment making the jury verdict the court’s judgment; the judgment was later deemed invalid.
- A second purported judgment was signed on Oct. 14, 2009 purporting to enter judgment for $21,733,411 plus fees and costs; it did not vacate the first judgment.
- Post-trial motions were filed; the trial judge later ruled the second judgment a nullity; there was confusion about proper defendants and how to compute costs and fees.
- The court dismissed the appeals for lack of a valid final judgment and remanded for entry of a proper final judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a valid final judgment exists for appellate jurisdiction | Input/Output contends a final judgment exists or can be perfected on remand. | Greatbatch argues no valid final judgment existed to support an appeal. | Appeals dismissed for lack of a valid final judgment; no appellate jurisdiction. |
| Effect of the first and second judgments on finality | IO contends the second judgment cures or supersedes the first. | Greatbatch argues the second judgment did not validly amend or vacate the first. | First judgment defective; second judgment nullity; no valid final judgment exists. |
| Are post-trial rulings subject to unrestricted appeal when there is no final judgment | IO seeks review of post-trial rulings as part of appeal from a final judgment. | Greatbatch argues interlocutory post-trial rulings are not appealable absent finality. | Interlocutory post-trial rulings are not properly before this court absent a valid final judgment. |
| Disposition on remand | If remand is necessary, a valid final judgment should be entered on remand. | Defendants seek dismissal with remand for proper final judgment entry. | Appeals dismissed without prejudice; remand to permit entry of a proper final judgment. |
Key Cases Cited
- Blanke v. Duffy, 927 So.2d 540 (La.App. 5 Cir. 2006) (final judgment must be precise, definite and identify the decretal relief)
- Borg-Warner Acceptance Corp. Through Borg-Warner Leasing v. Whitlow Truck Center, Inc., 508 So.2d 857 (La.App. 5 Cir. 1987) (fatally defective judgments lack ascertainable relief and party against whom enforced)
- Sporl v. Sporl, 788 So.2d 682 (La.App. 5 Cir. 2001) (unrestricted appeal requires a final judgment; interlocutory rulings reviewability)
- Scott v. State, 525 So.2d 689 (La.App. 1 Cir. 1988) (final judgment requirement and proper decretal language for appeal)
- Wadsworth v. Alexius, 99 So.2d 77 (La. 1958) (void proceedings render all further actions without legal effect)
- Johnson v. Mount Pilgrim Baptist Church, 934 So.2d 66 (La.App. 1 Cir. 2006) (clarity of judgment and delineation of relief matter for finality)
- Sporl v. Sporl, 788 So.2d 682 (La.App. 5 Cir. 2001) (unrestricted appeal right hinges on valid final judgment)