Uthe Technology Corp. v. Aetrium, Inc.

The one satisfaction rule will not preclude a plaintiff’s suit for additional damages against other defendants related to the same injury if the remedy in the second suit was not available in the first case and if court offsets the previously awarded damages from the subsequent claims.

Aetrium, Inc. conspired with unnamed individuals in Singapore (foreign defendants) to poach customers from Uthe Technology Corp. In 1993, Uthe filed suit against both defendants in federal court alleging violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). The Uthe’s RICO suit against Aetrium was stayed pending Uthe’s compelled arbitration with the foreign defendants in Singapore. Following the arbitration, which resulted in a $9 million award for Uthe that was paid in full, Uthe renewed their RICO claim against Aetrium. The district court granted summary judgment in favor of Aetrium, holding that an award of treble damages under RICO would violate the “one satisfaction rule,” an equitable principle aimed at preventing double recovery of damages arising from the same injury. On appeal, the Ninth Circuit reversed the district court’s summary judgment holding that the one satisfaction rule will not be violated as the arbitration’s award was not a full satisfaction of Uthe’s RICO claim. The panel noted that treble damages were not available to Uthe in the Singapore arbitration and the court may offset the arbitration’s award from the already awarded RICO damages. In this way, Uthe may fully satisfy its injury. REVERSED AND REMANDED.