Affirming Deference: Standards for New Trials and Jury Verdict Reviews in Feliciano-Muñoz v. Rebarber-Ocasio

Introduction

Feliciano-Muñoz v. Rebarber-Ocasio is a First Circuit appellate decision issued on April 23, 2025. At its core, the case arises from a dispute over the 2016 sale of majority shares in Air America, Inc., a regional Puerto Rican airline. Plaintiffs Luis Feliciano-Muñoz and Air America sued Fred Rebarber-Ocasio under Puerto Rico contract law, alleging misrepresentation as to aircraft condition and a refusal to pay for agreed repairs. Rebarber countersued Feliciano, his wife Christel Bengoa, and their conjugal partnership, claiming that Feliciano’s management of the airline constituted gross negligence. After a nine-day jury trial, all verdicts went in Rebarber’s favor—$534,836 awarded for gross negligence and $141,400 jointly assessed against Bengoa and the conjugal partnership.

The appellants challenged (1) the sufficiency of the evidence, (2) alleged trial-court errors, (3) the size of the damages award, and (4) judicial bias. They sought a new trial or, alternatively, remittitur under Federal Rule of Civil Procedure 59. The District Court denied relief in a thorough opinion, and the First Circuit affirmed.

Summary of the Judgment

The First Circuit, speaking through Chief Judge Barron, applied the abuse-of-discretion standard to the denial of the new-trial motion and reviewed jury-verdict challenges with deference. Key holdings:

The jury’s breach-of-contract verdict was not against the weight of the evidence where conflicting testimony and credibility calls are the province of the jury.
The jury’s gross-negligence finding was supported by evidence of mismanagement—failure to hold shareholder meetings, unauthorized loans, use of corporate funds for personal expenses, and falsified records.
Alleged trial-court errors in cross-examination scope, impeachment by clerical error, jury instructions on gross negligence, and prejudicial testimony were either waived or not abuses of discretion.
The damage award was neither “double recovery” nor so excessive as to shock the conscience. Appellants failed to meet the “heavy burden” to set it aside.
Allegations of judicial bias lacked factual support and did not demonstrate an “abiding impression” of partiality.

Analysis

1. Precedents Cited and Their Influence

The court relied heavily on established standards for reviewing new-trial motions and jury verdicts:

Blomquist v. Horned Dorset Primavera (925 F.3d 541): Abuse-of-discretion review of new-trial denials and convergence with JMOL standards when challenging evidentiary sufficiency.
Correia v. Feeney (620 F.3d 9): Deference to trial-court judgments on whether a verdict is against the weight of the evidence.
Sailor Inc. F/V v. City of Rockland (428 F.3d 348) & Rivera Castillo v. Autokirey (379 F.3d 4): “Manifest miscarriage of justice” test for ordering new trials.
Dimanche v. Mass. Bay Transp. Auth. (893 F.3d 1): Merger of new-trial and JMOL standards where evidence sufficiency is challenged.
Wagenmann v. Adams (829 F.2d 196): High threshold for disturbing a jury’s damage award—must be “grossly excessive” or “shocking to the conscience.”
Smith v. Kmart Corp. (177 F.3d 19): Reinforces deference to jury’s damage assessment unless it “denies justice to permit it to stand.”
Currier v. United Techs. Corp. (393 F.3d 246): “Heavy burden” on the party seeking to upset an award.

These precedents guided the court’s thorough deference to the jury’s credibility choices and to the District Court’s gatekeeping of new-trial and remittitur motions.

2. Legal Reasoning

The First Circuit’s analysis proceeded in four steps:

Weight-of-Evidence Review: The court affirmed that where evidence conflicts or a witness’s credibility is at stake, a new trial is unwarranted absent a “manifest miscarriage of justice.” The appellants’ so-called “unchallenged” evidence was, in fact, subject to cross-examination and direct challenge by Rebarber’s witnesses.
Abuse of Discretion on Trial Management: Alleged errors in questioning scope, impeachment methods, and jury instruction clarity were either waived or within the trial judge’s broad discretion.
Damages Scrutiny: The court reaffirmed that damages need only have a “substantial basis in the evidence.” Appellants pointed to no binding authority to cap recovery at the stock’s market value or to preclude goodwill damages.
Judicial Bias Claim: On appeal, parties must show objective facts giving rise to an “abiding impression” of partiality. Isolated statements by the trial judge, grounded in the record and pertinent to credibility, fell far short.

3. Impact on Future Cases

This decision reinforces several important principles:

Trial judges enjoy wide latitude in managing cross-examination, impeachment, and jury instructions; appellate courts will not lightly second-guess.
Parties challenging jury verdicts face a formidable “manifest miscarriage of justice” standard—mere disagreement with credibility determinations or damage calculations will not suffice.
Remittitur remains an extraordinary remedy; parties must carry the “heavy burden” of demonstrating that an award is grossly excessive relative to the evidentiary record.
Allegations of judicial bias must rest on objective, record-based instances of conduct creating a pervasive atmosphere of partiality.

As a practical matter, Feliciano-Muñoz v. Rebarber-Ocasio will deter litigants from filing new-trial motions based solely on contested testimony or perceived evidentiary slights, and it underscores the uphill climb for remittitur.

Complex Concepts Simplified

Abuse of Discretion: Appellate courts give trial judges wide leeway; they intervene only when a decision is arbitrary, unreasonable, or based on an error of law.
Manifest Miscarriage of Justice: A verdict so against the weight of the evidence that letting it stand would shock the judicial conscience.
Remittitur: When a court reduces (rather than outright vacates) an excessive damage award, offering the plaintiff the choice between accepting a lower sum or facing a new trial.
Gross Negligence vs. Ordinary Negligence: Gross negligence involves a conscious and voluntary disregard for the need to use reasonable care, implying a “reckless indifference” to consequences.
New-Trial Motion (Rule 59): Must be filed within 28 days of judgment. Grounds include errors of law, newly discovered evidence, misconduct, and verdicts against the weight of the evidence.

Conclusion

Feliciano-Muñoz v. Rebarber-Ocasio reaffirms the judiciary’s strong presumption in favor of sustaining jury verdicts and upholding trial-court discretion on new-trial and remittitur motions. By faithfully applying First Circuit precedents, the panel clarified that conflicting evidence and damage calculations—even where debatable—do not justify a second bite at the apple absent a compelling demonstration of injustice. This decision thus serves as a guidepost for litigators weighing post-verdict strategies and for judges safeguarding the boundaries of fair trial management.