Cnh America, LLC v. Ligon Capital, LLC, and Hti Hydraulic Technologies, LLC

Summary

The court affirmed a judgment awarding $3.8 million in compensatory damages and $7.6 million in punitive damages on fraudulent-suppression claims. It held that CNH had a duty to disclose its decision to replace HTI because HTI asked sufficiently specific questions and CNH made statements that required truthful and complete qualification; substantial evidence supported concealment, inducement, and injury. The court also held that CNH waived its argument concerning Ligón's separately asserted claim, that any error in the jury instruction was nonprejudicial, and that the punitive-damages award did not require remittitur. Justices Shaw and Bryan, dissenting, would have held that CNH had no duty to disclose because HTI did not ask a sufficiently direct question and understood that CNH made no commitment for a definite period.