Raedle v. Credit Agricole Indosuez
670 F.3d 411
2d Cir.2012Background
- Raedle sued CAI and supervisors Shaiman and Smith for tortious interference with a prospective job offer from Dreyfus.
- Raedle was fired by CAI in 2001 for alleged performance problems; he then received and lost a Dreyfus offer after CAI/Dreyfus discussions.
- The district court granted Raedle a new trial under Rule 59(a)(1)(A) after the first trial yielded a defense verdict.
- At retrial, Raedle prevailed and was awarded damages; defendants moved for post-trial relief and the court denied certain aspects.
- The Second Circuit reversed, holding the district court abused its discretion by granting a new trial and remanded to reinstate the first verdict in defendants’ favor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused discretion by granting a new trial on weight of the evidence. | Raedle; weight-of-evidence verdict warrants new trial only for egregious misrule. | CAI/Shaiman; credibility issues and weight of evidence supported a new trial. | Yes, district court abused discretion; first verdict reinstated. |
| Whether the verdict hinged on credibility of a single witness and whether that justified a new trial. | Raedle contends credibility favored the defense verdict. | Credibility of Thunelius was central; court could weigh credibility. | Abuse of discretion; jury credibility should not be replaced absent egregious result. |
| Whether the New York tortious-interference standard requires a false, improper, or malicious communication as to be actionable. | Negative references were tortious if false/improper. | Negative references may be honest, non-tortious evaluations. | Not dispositive; case hinges on credibility and whether statements were tortiously improper. |
Key Cases Cited
- Farrior v. Waterford Bd. of Educ., 277 F.3d 633 (2d Cir. 2002) (abuse-of-discretion standard for new-trial motions; weight of evidence)
- DLC Mgmt. Corp. v. Town of Hyde Park, 163 F.3d 124 (2d Cir. 1998) (jury credibility deference; avoid reversing credibility determinations)
- Metromedia Co. v. Fugazy, 983 F.2d 350 (2d Cir. 1992) (deference to jury on credibility; rare to disturb verdict)
- Sorluc co v. New York City Police Department, 971 F.2d 864 (2d Cir. 1992) (illustrates when a court may review credibility determinations on new-trial motions)
- United States v. Landau, 155 F.3d 93 (2d Cir. 1998) (credibility assessments entitled to deference; caution in reweighing)
- Song v. Ives Labs., Inc., 957 F.2d 1041 (2d Cir. 1992) (exception where credibility requires new trial in unique displacement)
- Miller v. Mount Sinai Medical Center, 733 N.Y.S.2d 26 (1st Dep’t 2001) (limits on tortious interference claims based on honest assessments)
- Jacobs v. Continuum Health Partners, Inc., 776 N.Y.S.2d 279 (1st Dep’t 2004) (limits on evaluating false/defamatory references in interference claims)