114 F.4th 1212
11th Cir.2024Background
- Taxinet Corporation (a South Dakota company with a successful taxi-hailing app in Ecuador) partnered with Santiago Leon and others to secure a government concession for an exclusive taxi-hailing app in Mexico City.
- No written joint venture agreement existed, but the parties collaborated closely until Leon sought to remove Taxinet and continue alone, forming a new Mexican entity (Lusad) owned almost entirely by Leon.
- Taxinet sued Leon in Florida for claims including breach of joint venture, tortious interference, and unjust enrichment; only the unjust enrichment claim survived to trial, along with Leon's counterclaims.
- At trial, the jury awarded Taxinet $300 million for unjust enrichment, relying on speculative and hearsay-based valuation evidence. Leon was awarded $15,000 on his counterclaim.
- The district court set aside the unjust enrichment verdict under Rule 50(b), finding the damages based on inadmissible hearsay (primarily a $2.4 billion Goldman Sachs valuation), but ordered a new trial on the claim due to some admissible, though insufficient, evidence.
- District court also granted summary judgment against all of Taxinet’s contract-based and statutory claims, ruling the alleged joint venture was barred by Florida's statute of frauds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for unjust enrichment | Taxinet conferred benefits; damages supported by valuation | Damages award based on inadmissible, speculative testimony | Evidence insufficient for $300M damages due to hearsay; new trial allowed |
| Admissibility of Goldman Sachs valuation | Valuation testimony admissible as owner’s opinion | Testimony merely repeated hearsay report; should be excluded | District court did not abuse discretion excluding as hearsay |
| Existence/enforceability of joint venture (statute of frauds) | Oral agreement allowed, performance within one year possible | No writing, venture required performance beyond one year | Statute of frauds barred claims; summary judgment for Leon |
| Right to new trial on unjust enrichment | Sufficient evidence of benefit; admissible damages evidence | Futile, as no other evidence of value could be provided | New trial granted due to procedural posture and some evidence |
Key Cases Cited
- Pincus v. Am. Traffic Sols., Inc., 333 So. 3d 1095 (Fla. 2022) (outlines the elements of unjust enrichment under Florida law)
- F.H. Paschen, S.N. Nielsen & Assocs. LLC v. B&B Site Dev., Inc., 311 So. 3d 39 (Fla. 4th DCA 2021) (describes proper measure of unjust enrichment damages)
- Agritrade, LP v. Quercia, 253 So. 3d 28 (Fla. 3d DCA 2017) (reaffirms elements of unjust enrichment)
- Montage Grp., Ltd. v. Athle-Tech Comput. Sys., Inc., 889 So. 2d 180 (Fla. 2d DCA 2004) (need for a reasonable measure—"yardstick"—of damages)