Narkiewicz-Laine v. Doyle

Federal 7th Circuit Court
Civil Court
Damages
Citation
Case Number: 
No.18-2535
Decision Date: 
July 19, 2019
Federal District: 
N.D. Ill., E. Div.
Holding: 
N.D. Ill., E. Div.

 

Dist. Ct. did not abuse its discretion in reducing plaintiff’s damages from $420,000 to $300,000 in plaintiff’s Copyright Act and common law claims for trespass and conversion, where plaintiff alleged that defendant wrongfully discarded plaintiff’s artwork and other items in rental storage unit after plaintiff had failed to pay rent on said unit. Jury awarded Plaintiff $120,000 in damages for four pieces of artwork protected under Copyright Act, and $300,000 in plaintiff’s common law claims for loss of all artwork and other belongings stored in rental unit. Instant reduction was proper to avoid plaintiff receiving double recovery, where jury’s damages assessment in common law verdict included same artwork covered under Copyright Act. Dist. Ct. also did not err in allowing defendant to question plaintiff about his 2003 conviction for making false statement to FBI, even though said conviction was over 10 years old. There is no absolute bar to admitting conviction that is over 10 years old, and no reversible error occurred, where use of said conviction did not skew jury’s verdict since plaintiff had obtained partial favorable verdict from jury.