Not Applying Federal Rules of Civil Procedure Cost Medical Laboratory a Possible $1M Damages Award

Acadian Diagnostic Laboratories, L.L.C., (Acadian) and Quality Toxicology, L.L.C., (QT) entered into two agreements to create a reciprocal testing arrangement. In each arrangement, QT was to collect the funds for testing and pay Acadian an agreed-upon percentage. QT, however, failed to pay Acadian the full amount owed. Acadian filed a lawsuit for breach of contract. The district court granted Acadian partial summary judgment on the breach-of-contract claims and made some conclusions about what payment QT owed for a portion of the unpaid tests. The remainder of the damages was left up to a jury. Shortly after the jury awarded Acadian $269,706.50, the district court judge presiding over the case passed away. Fifteen months later the district court entered a final judgment for the jury damages but did not mention the original judge’s opinion or damages calculation. Both parties appealed. The Fifth Circuit affirmed the summary judgment for QT based on a lack of evidence to support its claims. The court affirmed the summary judgment for Acadian because the company failed to take advantage of the numerous opportunities available to “ensure a district court gets its post-jury-trial judgment right”. You can read the full details on the case, including the Federal Rules of Civil Procedure options Acadian should have chosen, here.