Wang v. Ehang Holdings Limited

Background

The opinion addressed an apparent inconsistency in the jury’s special verdict. The jury found that Gary Wang proved all elements of a false-promise claim against Hauzhi Hu. It also found that Guangzhou EHang Intelligent Technology Co., Ltd. and EHang Holdings Limited were legally responsible for Hu’s false promise. The jury did not find all elements of false promise against Derrick Yifang Xiong, Shang-Wen Hsiao, or Richard Jian Liu.

False promise was the only claim that could support punitive damages. The jury was instructed to decide whether a defendant acted with malice, oppression, or fraud if the defendant’s conduct under that claim harmed Wang. The jury found that Hauzhi Hu, Guangzhou EHang Intelligent Technology Co., Ltd., and EHang Holdings Limited acted with one of those states of mind. It also marked the same finding for Shang-Wen Hsiao and Richard Jian Liu, even though it had found them not liable for false promise.

The jury awarded punitive damages of $5,000,000 against Hauzhi Hu and $10,000,000 against EHang Holdings Limited. It entered "$0.00" for Guangzhou EHang Intelligent Technology Co., Ltd. and left the punitive-damages lines blank for Derrick Yifang Xiong, Shang-Wen Hsiao, and Richard Jian Liu.

Court’s Analysis

The court explained that when answers in a special verdict appear inconsistent, it must try to reconcile them through a fair reading of the verdict. A new trial is appropriate only if the inconsistency cannot be reconciled.

The court found the verdict could be harmonized. It interpreted the blank punitive-damages lines for Shang-Wen Hsiao and Richard Jian Liu as showing that the jury did not intend to find them liable for punitive damages. The court reasoned that the jury likely found they had the required mental state only in the event that they were found liable for false promise, but that finding never occurred. The different treatment of Guangzhou EHang Intelligent Technology Co., Ltd.—for which the jury entered "$0.00"—supported that interpretation.

The court further ruled that even if the jury intended its mental-state findings to impose punitive-damages liability on Shang-Wen Hsiao and Richard Jian Liu, those findings had to be disregarded as surplusage. Because liability for false promise was a prerequisite to punitive damages in this case, the jury’s finding that Wang had not proved false promise against those two defendants resolved the issue and made additional findings unnecessary.

Disposition

The court found that the apparent inconsistency in the special verdict could be harmonized. It also ruled that the jury’s findings concerning malice, oppression, or fraud for Shang-Wen Hsiao and Richard Jian Liu had to be disregarded as surplusage.