Sampliner v. Motion Picture Patents Co.
Headline: Court reverses directed verdict and remands for a jury to decide whether an attorney’s purchase of a client’s antitrust claim was buying a lawsuit to profit, affecting an attorney who accepted a client’s claim as payment.
Holding: The Court held the trial judge wrongly directed a verdict, reversed the judgment, and remanded so a jury should determine whether an attorney’s assignment of a client’s antitrust claim was a valid settlement of debt rather than an improper purchase.
- Requires juries to decide disputed facts about why an attorney accepted a client’s claim.
- Limits judges from directing verdicts when a timely jury request exists.
- Affects attorneys who take client claims as payment for fees.
Summary
Background
An Ohio film supply corporation transferred to an attorney its claim for damages from an alleged unlawful combination that harmed the company’s business. The attorney, who had been the company’s general counsel and was owed fees, accepted the assignment in lieu of payment and later sued in federal court for $750,000. The defendants argued the assignment was void because an attorney had bought the claim to litigate it — what they called buying a lawsuit to profit — and the trial judge directed a verdict for the defendants after finding the attorney bought the claim to sue.
Reasoning
The main question was whether the trial court should have taken the case away from the jury and treated the attorney’s acquisition as an improper purchase. The Supreme Court explained that the attorney had asked to go to the jury and that there was substantial evidence suggesting the assignment was given to settle an existing debt for legal services, not merely to speculate on litigation. Because the factual dispute existed and the request to submit those facts to a jury was timely, the Court held the directed verdict was improper and reversed the judgment.
Real world impact
The ruling sends the case back to the trial court for further proceedings and preserves the jury’s role in deciding contested facts about why an attorney took an assignment. It affects attorneys who accept client claims as payment and limits a judge’s power to remove contested factual issues from a jury when a timely jury request has been made. The decision is procedural and does not resolve the ultimate merits of the antitrust claim.
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