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Burgoyne v. GoldsteinEnright CA1/2
Plaintiff Henry M. Burgoyne III and Karl Kronenberger co-founded a law firm from which Kronenberger later ejected Burgoyne. In this action, Burgoyne seeks to recover from the law firm’s accountants damages that he alleges the accountants caused him in the aftermath of this breakup. A jury that heard the evidence agreed with Burgoyne. They found the accountant, David Woo, and his firm, GoldsteinEnright, liable on breach of contract, professional negligence, and breach of fiduciary duty causes of action, and they awarded Burgoyne $292,000 in damages. Then the trial court entered judgment notwithstanding the verdict (JNOV) on the ground that the jury’s damages award was not supported by substantial evidence. Because the question on a JNOV motion is whether the record contains substantial evidence that the plaintiff suffered damages in some amount—not whether the evidence supports the specific amount of damages awarded—we reverse.

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