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REASONING
The United States Court of Appeals, Eighth Circuit affirmed the ruling of the United States District Court for the Eastern District of Missouri in this case. For each of the new challenges made by Yannacopoulos in the appeal, the court provided sound reasoning for their ruling.
1) “Yannacopoulos alleged that two pieces of evidence critical to his tortious-interference claim were erroneously excluded.” (FindLaw)
a) First, a letter/legal opinion of a Greek lawyer, Gregory Mourgelas, who was employed by GD, which could have proved that GD was obligated to pay him commissions or commission equivalents. The court reasoned that the exclusion of the letter was justified since; this exclusion could not be considered “an abuse of discretion given the posture of this case.” (FindLaw) The excluded letter was not evidence that a contract for commissions existed between Yannacopoulos and GD.
b) Secondly, he argued “that it was error for the Court to exclude evidence of an alleged “bait-and-switch” scheme employed by GD.” (FindLaw) The court reasoned that it is unlikely that the admission of said excluded evidence would have had a substantial positive effect on the case. “In fact, establishing that a bait-and-switch scheme was employed by GD could suggest only that, if a contract existed, GD needed to break its contract with Yannacopoulos in order to carry out its scheme.”
2) “Yannacopoulos argued that the District Court's denial of his motion for judgment as a matter of law on GD's contract, RICO, and fraud counterclaims was error.” (FindLaw) The court reasoned that on appeal, the evidence in the light most favorable to the prevailing party was reviewed carefully and the Court was persuaded that sufficient evidence was presented by GD on each of its counterclaims to sustain the District Court’s ruling.
3) Next, Yannacopoulos claimed” that the District Court erred by failing to instruct the jury properly in two instances.” (FindLaw) One, by refusing “to instruct the jury that no United States law barred GD from paying him commissions” and secondly, by refusing “to instruct the jury on the definition of procuring cause.” (FindLaw) After examining the circumstances and Missouri law, the appeals court reasoned that the District Court committed no error in either respect.
4) In his final argument, Yannacopoulos claimed “that the District Court erred by refusing to allow him to investigate alleged juror misconduct.” (FindLaw) The appeals court noted that Yannacopoulos failed to object to the admonitions given to the jury by the District Court, or to the continuation of jury deliberation. He made no request to voir dire the jury panel, or to question that particular jury member. Instead, he waited until after the verdict was returned to raise this issue. They said that when a party waits until the end of a case to complain of juror misconduct, as Yannacopoulos did, the objection is waived, and a decision to reverse the District court’s ruling would be made only if they believed it was a plain error. “Plain error is error which has a serious effect on the fairness of the proceedings.” (FindLaw) Therefore, the court reasoned that given the aforementioned facts the District Court's use of preemptive admonitions was not plain error. And hence they affirmed the court’s ruling.
CONCLUSION
Yannacopoulos appealed to the United States Court of Appeals, Eighth Circuit because after a six-week trial, the jury of the United States District Court for the Eastern District of Missouri returned a verdict against him on each of his six claims against GD, and in favor of GD on its breach-of-contract claim. His requests were that the judgment be reversed and a new trial granted due to errors made by the Court. Yannacopoulos, however, could not produce any new/additional evidence to aide his claims in this appeal. The court hence affirmed the ruling of the lower court.
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