Christie Manson & Woods Ltd. v. Minor

MEMORANDUM

Appellants Christie’s Inc. (“Christie’s”) and Christie Manson & Woods Ltd. (“CMW”) appeal the district court’s entry of judgment following a jury trial. Appellee Halsey Minor (“Minor”) is an individual art collector who bid over $12 million for six paintings at two auctions held in the Summer of 2008 by Christie’s and CMW respectively. During this time, Minor also consigned a collection of artworks by Richard Prince (the “Prince Artworks”) with a Christie’s sibling-company, Haunch of Venison Ltd. (“HOV”) in London. Appellants contend that the district court improperly instructed the jury on several issues of California law.

Appellants assert that the district court erred in: (1) refusing to instruct the jury that Christie’s had the right to take possession of the Prince Artworks from HOV pursuant to California Commercial Code section 9203(b)(3)(A); (2) instructing the jury that any collateral rights Christie’s may have had in the Prince Artworks were superceded if the jury found that Christie’s represented to Minor that it would release the artworks to him; (3) directing the jury to disregard certain testimony contrary to the court’s instructions; and (4) limiting the…