Hyundai Motors America, Inc. v. Ace A Dent, Inc.

MEMORANDUM ***

Appellant Hyundai challenges the district court’s directed verdict in favor of *149 Daniel and David Hawley. The Hawleys cross-appeal the court’s denial of their motion for sanctions. We exercise jurisdiction under 28 U.S.C. § 1291 and affirm the district court’s rulings.

Sitting in diversity, we apply the substantive law of Nevada and the federal procedural and evidentiary rules. We review de novo the district court’s directed verdict under Federal Rule of Civil Procedure 50(a), reviewing all of the evidence in the record and drawing all reasonable inferences in favor of Hyundai, the nonmoving party. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150-51 , 120 S.Ct. 2097 , 147 L.Ed.2d 105 (2000).

Under Nevada law, for there to be a legally sufficient evidentiary basis to hold the Hawleys personally liable for Ace-A-Dent’s fraud, Hyundai was required to establish that the Hawleys were the corporation’s alter egos. Nevada defines alter ego liability as follows:

Lorenz v. Beltio, Ltd., 114 Nev. 795 , 963 P.2d 488, 496 (1998) (per curiam) (internal quotation marks omitted).

Hyundai, however, did not show that the Hawleys influenced and governed…