Judge Shira Scheindlin
Snyder brought an action against Wells Fargo Bank N.A., a successor-in-interest to Wachovia Bank N.A. for breach of contract and breach of fiduciary duty. Snyder claimed to have suffered investment losses as a result of Wachovia’s failure to exercise reasonable care, skill and caution in making investment decisions regarding his Investment Management Agreement with Wachovia. A jury awarded Snyder $7,437 in damages for breach of contract and $724,999 in damages for breach of fiduciary duty. Wachovia moved to set aside the jury’s verdict on Snyder’s breach of fiduciary duty claim and Snyder cross-moved to alter or amend the judgment to add statutory interest. The court granted both motions, finding that the jury’s determination that Wachovia breached its fiduciary duty to Snyder was without evidentiary support and appeared to have been on the basis of conjecture or confusion rather than any theory of the case put forth by Snyder. The court also amended the judgment to add statutory interest at the rate of nine percent from the earliest date of the breach of contract, through the date of the amended judgment.
