Rhee v. Sante Ventures

Background

Plaintiff Youngjoo Rhee moved for reconsideration of the court’s earlier Opinion and Order, which granted defendant SHVMS, LLC, doing business as SANTE VENTURES, a new trial or remittitur. Remittitur is a reduction of a jury’s damages award. The earlier order concluded that the jury made two specific, quantifiable errors in calculating Rhee’s compensatory damages.

Reasons for Denying Reconsideration

The court applied the strict standard for reconsideration. Such a motion generally requires an intervening change in controlling law, genuinely new evidence, or a need to correct clear error or prevent serious injustice.

First, Rhee argued that the court could not alter the jury’s damages award because the award did not “shock the judicial conscience.” The court explained that this standard applies when no specific error can be identified. Because the court had identified two specific errors in the jury’s damages calculations, it was not required to apply that standard.

Second, Rhee relied on materials available on the Pennsylvania Public School Employees’ Retirement System’s website, which she argued showed that the system had committed to invest in two of the defendant’s funds before her termination. The court rejected this argument because the materials were available before the relevant judgment and were not evidence the jury had received at trial. The court also stated that evidence previously available to the party seeking reconsideration does not qualify as newly discovered evidence for this purpose.

Third, Rhee argued that the vesting clause in her offer letter was ambiguous because “close” could refer to completing a sales presentation. The court disagreed. Reading the bonus provision as a whole, it concluded that “close” referred to an investor’s binding commitment to contribute capital, not merely a presentation or request for investment. The court therefore concluded that Rhee had not shown that the clause was ambiguous.

Finally, Rhee repeated her argument that the defendant could not use her $300,000 payment to reduce the award because it had not pleaded setoff as a counterclaim or affirmative defense. The court had already rejected that argument, noting that Rhee had not raised it in her motion papers and that setoff did not apply because she had not incurred a debt to the defendant when she received the payment. The reconsideration motion did not address that reasoning.

Ruling and Effect

The court denied Rhee’s motion for reconsideration. It also clarified that any new trial would be limited to damages. The prior jury’s determination that the defendant was liable for breach of contract would remain binding, while a new jury could hear evidence and decide the amount of Rhee’s damages. The parties could present new evidence consistent with the existing Joint Pretrial Order and could seek changes to that order or file motions about particular evidence or legal issues before trial.

Rhee was ordered to notify the court within seven days whether she would accept the reduced verdict or choose a retrial on damages. If she accepted the reduced verdict, she had to submit a proposed judgment reflecting the reduced damages and prejudgment interest calculations. The clerk was directed to close the reconsideration motion.