Chugh v. Kalra

Summary

The court held that the plaintiff's claims were not barred by the federal compulsory-counterclaim rule because the prior federal action had not produced a merits adjudication and applying the rule would be inequitable. It also held that incorporation of entities did not, as a matter of law, terminate the parties' alleged overarching partnership, and that sufficient evidence supported the jury's finding that a partnership existed. The court reversed the libel damages and punitive-damages awards because the expert's lost-profits opinion lacked a factual basis and the erroneous damages instruction was not harmless, remanding for a new libel trial and damages hearing while affirming the judgment otherwise.