Uploaded April 2025 | Updated September 2026, 2 weeks ago
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Walt Disney Productions v. Air Pirates
United States Court of Appeals for the Ninth Circuit
581 F.2d 751 (1978), 439 U.S. 1132
Undue influence involves using persuasion, a special relationship, or position of power to compel another to enter an agreement. In more versus more, a son convinced his ailing parents to convey their properties at below market rates. Will undue influence void the transactions?
John and Joyce Moore had four children and owned a farm and homestead.
Their son, Steven, was the only sibling who lived on the land and helped run the family farm. Steven was also named as his parents' financial and medical power of attorney.
As part of their estate plan, the Moores established a trust to benefit their children. The trust stipulated that upon their deaths, Steven would inherit the farm equipment and farmland where he resided.
The remaining property would be divided among the other siblings to do with as they wished. Steven repeatedly warned his mother that his siblings would sell the land and destroy the family farm.
While Joyce was hospitalized with a severe abdominal infection, and John lay on his deathbed, Steven approached his parents and persuaded them to sign two contracts, selling their homestead and farmland to Steven's son, Jebediah.
The contracts provided for below market prices, nominal interest, and extended payment terms.
Steven never told his siblings about the transactions.
Following John's death, Joyce filed suit against Steven to set aside the contracts on the grounds that Steven exerted undue influence over John and Joyce.
After a trial, the jury returned a verdict in Steven's favor. However, the jury had been incorrectly instructed that Joyce bore the burden of proving undue influence.
Joyce appealed, arguing that this was reversible error.
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Get more case briefs explained with Quimbee. Quimbee has over 42,700 case briefs (and counting) keyed to 988 casebooks ► quimbee.com/case-briefs-overview
Walt Disney Productions v. Air Pirates
United States Court of Appeals for the Ninth Circuit
581 F.2d 751 (1978), 439 U.S. 1132
Undue influence involves using persuasion, a special relationship, or position of power to compel another to enter an agreement. In more versus more, a son convinced his ailing parents to convey their properties at below market rates. Will undue influence void the transactions?
John and Joyce Moore had four children and owned a farm and homestead.
Their son, Steven, was the only sibling who lived on the land and helped run the family farm. Steven was also named as his parents' financial and medical power of attorney.
As part of their estate plan, the Moores established a trust to benefit their children. The trust stipulated that upon their deaths, Steven would inherit the farm equipment and farmland where he resided.
The remaining property would be divided among the other siblings to do with as they wished. Steven repeatedly warned his mother that his siblings would sell the land and destroy the family farm.
While Joyce was hospitalized with a severe abdominal infection, and John lay on his deathbed, Steven approached his parents and persuaded them to sign two contracts, selling their homestead and farmland to Steven's son, Jebediah.
The contracts provided for below market prices, nominal interest, and extended payment terms.
Steven never told his siblings about the transactions.
Following John's death, Joyce filed suit against Steven to set aside the contracts on the grounds that Steven exerted undue influence over John and Joyce.
After a trial, the jury returned a verdict in Steven's favor. However, the jury had been incorrectly instructed that Joyce bore the burden of proving undue influence.
Joyce appealed, arguing that this was reversible error.
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![Schrems v. Data Protection Commissioner (Joined by Digital Rights Ireland) [Schrems I] | Law Case](https://i.ytimg.com/vi/U86aLpipVaM/mqdefault.jpg "Schrems v. Data Protection Commissioner (Joined by Digital Rights Ireland) [Schrems I] | Law Case
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Schrems v. Data Protection Commissioner (Joined by Digital Rights Ireland) [Schrems I]
European Court of Justice
Case C-362/14 (2015)
European Union regulations strictly control the transfer of personal data from data controlling entities in Europe to countries outside the EU referred to as third countries.
The regulations require third countries to ensure an adequate level of data protection.
In data protection commissioner versus Facebook Ireland Limited and Maximilian Schrems, the European Court of Justice considered whether the United States met this standard. In two thousand, the US and the EU negotiated an agreement called the Safe Harbor Principles to authorize private companies to transfer personal customer data from Europe to the states.
The European Commission issued a decision called an adequacy decision certifying that Safe Harbor guaranteed an adequate level of data protection for European citizens.
However, safe harbor allowed the American government unlimited access to personal data for national security and other purposes.
In two thousand thirteen, former government contractor Edward Snowden leaked information revealing that American security agencies engaged in extensive warrantless data collection and had direct access to the data held by major companies like Google and Facebook.
Austrian citizen, Maximilian Schrems, had a Facebook account. European Facebook users had to contract with Facebook Ireland, a Facebook subsidiary.
Facebook Ireland sent users personal data to Facebook in the US. Following the Snowden league, Shremes filed a complaint with Irelands data protection commissioner, that countrys data supervisory authority. Schrems asked the authority to prohibit Facebook Ireland from transferring his data to the US because US law didnt adequately protect personal data.
The authority rejected Schrems complaint because of safe harbor.
Schrems appealed to Irelands high court, which requested an opinion on the safe harbor decisions validity from the European Court of Justice.
The European Court invalidated the decision and referred the case back to the authority.
Thereafter, the US and EU negotiated a new agreement called Privacy Shield. The European Commission issued an adequacy decision approving Privacy Shield. Privacy Shield was similar to Safe Harbor, but created an ombudsperson to investigate data privacy complaints from European citizens.
Again, however, Privacy Shield allowed the federal government unlimited access to personal data for national security reasons.
Schrems refiled his complaint. The authority referred the case to Irelands high court, which again referred the case to the European Court of Justice for a preliminary ruling.
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