Justia Ohio Supreme Court Opinion Summaries
Articles Posted in Intellectual Property
Phoenix Lighting Group, L.L.C. v. Genlyte Thomas Group, L.L.C.
Phoenix Lighting Group, L.L.C. (Phoenix) sued Genlyte Thomas Group, L.L.C. (DCO) and obtained a jury verdict for tortious interference, misappropriation of trade secrets, and civil conspiracy. The jury awarded Phoenix compensatory and punitive damages, as well as reasonable attorney fees. The trial court awarded additional punitive damages for the misappropriation claim and enhanced the attorney fees by a multiplier of two.The Ninth District Court of Appeals affirmed the trial court's decision in part but reversed the application of the punitive-damages cap for the conspiracy claim, remanding the case for further proceedings. Phoenix requested postjudgment attorney fees, which the Ninth District did not specifically address but remanded the case for further proceedings consistent with its opinion.The Supreme Court of Ohio accepted jurisdiction over DCO's challenge to the enhancement of the attorney-fee award. The court reversed the Ninth District's affirmation of the enhanced attorney fees and remanded the case to the trial court to issue a final judgment granting Phoenix attorney fees in the amount of $1,991,507.On remand, the trial court awarded Phoenix postjudgment attorney fees and expenses. The Ninth District affirmed this award, concluding that the trial court had jurisdiction to consider postjudgment attorney fees and did not exceed its authority.The Supreme Court of Ohio reviewed the case and held that the trial court exceeded its authority by considering and granting Phoenix's motion for postjudgment attorney fees and expenses. The court reversed the Ninth District's judgment and remanded the case to the trial court with instructions to vacate its award of postjudgment attorney fees and expenses and to enter final judgment. View "Phoenix Lighting Group, L.L.C. v. Genlyte Thomas Group, L.L.C." on Justia Law
State v. Lalain
Defendant pleaded guilty to fifth-degree-felony theft of property valued at $500 or more but less than $5,000 for misappropriating intellectual property from his employer (Employer). As part of his sentence, the trial court ordered Defendant to pay restitution to Employer in the amount of $63,121, representing the costs of a company investigation and an accounting. The court of appeals affirmed the order of restitution. The Supreme Court reversed, holding (1) a trial court has discretion to base the amount of restitution in an appropriate case on the amount it orders on a recommendation of the victim, the offender, a presentence investigation report, and other information, but the amount ordered cannot be greater than the amount of economic loss suffered as a direct and proximate result of the commission of the offense; (2) a hearing on restitution is required only if the offender, victim, or survivor disputes the amount of restitution ordered; and (3) the trial court lacked authority in this case to order $63,121 in restitution. Remanded. View "State v. Lalain" on Justia Law