Kbx, Inc. Steven Michael Keith, Sr.

Summary

The court held that substantial evidence did not support the farmers’ conversion, deceit, constructive-fraud, conspiracy, or unjust-enrichment claims against KBX and the KBX Individuals. Because KBX paid TGI for the rice and the farmers had no direct contractual or communicative relationship with KBX, the court reversed and dismissed the judgment against those appellants. The court affirmed dismissal of KBX’s counterclaims but reversed the attorney-fee award and remanded for recalculation limited to fees directly resulting from spoliation.