Four years after a federal district judge in New York lambasted a product liability lawyer for going overboard in his closing arguments during a bellwether trial against Merck & Co. Inc., an appeals court has vacated sanctions against the attorney.

The U.S. Court of Appeals for the Second Circuit ruled Monday that the trial judge overstepped his authority when he slapped a $2,500 sanction on Gary Douglas, name partner of New York plaintiffs firm Douglas & London.

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