Albee v. Trott

CourtSuperior Court of Maine
DecidedOctober 20, 2015
DocketCUMcv-14-185
StatusUnpublished

This text of Albee v. Trott (Albee v. Trott) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Albee v. Trott, (Me. Super. Ct. 2015).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS. CIVIL ACTION DOCKET NO. CV-14-185

ALICE ALBEE, ) ) Plaintiff ) STATE OF MA\ME ) Cumtwa!'f~"A ~ ~IAN~ {)flee-- v. ) ) OCT .212015 JOHN TROTT, JR., et al., )

Defendants ) ) RECEIVED ORDER ON GINN PORTLAND, LLC'S MOTION FOR SUMMARY JUDGMENT

Defendant Ginn Portland, LLC's ("Ginn") has moved for summary judgment on

Plaintiff Alice Albee's negligence claim against Ginn as the owner of the commercial property

where she sustained the injuries for which she seeks damages in this action. Oral argument

was held on October 6, 2015.

Based on the entire record, Ginn's motion for summary judgment is granted.

I. Background

A. Undisputed Facts

For the purpose of summary judgment, the following facts in this case are not in dispute

as between the Plaintiff Alice Albee and Defendant Ginn:

On October 12, 2011, a vehicle operated by Defendant New Bern Transport

Corporation ("New Bern") and driven by Defendant John Trott, Jr. struck Plaintiff, resulting in

her injury. (Def.'s Supp. S.M.F. ~ 2.) The incident occurred on the paved parking area

adjacent to a 7-Eleven convenience store and gas station located at 704 Congress Street in

Portland, Maine. Id. ~~ 1, 8. New Bern, through its employee Trott, was delivering Pepsi

products to the 7-Eleven store at the time of Plaintiffs injury. Id. ~ 3. Ginn is the owner of

1 the property that encompasses the store and paved parking area where the accident happened.

Id. ~ 5.

Plaintiff filed a negligence complaint against Trott, New Bern, Pepsico, Inc., and Pepsi

Bottling Group, Inc. on April 16, 2014. (Compl. 1.) On June 11, 2104, Plaintiff amended her

complaint, dropping Pepsico, Inc. and Pepsi Bottling Group, Inc. from the lawsuit and adding

Ginn. (Am. Compl. 1). Plaintiff has not brought suit against the tenant who rents the

property from Ginn and operates the 7-Eleven convenience store.

On July 6, 2015, Ginn moved for summary judgment, claiming it is entitled to judgment

as a matter oflaw on Plaintiffs claim. Plaintiff Albee filed a timely opposition.

II. Analysis

A. Applicable Law

Plaintiff has brought a negligence claim against Ginn as the landlord of the property

whe~e her injury occurred. "To establish a prima facie case of negligence, a plaintiff must

establish that a duty was owed, the duty was breached, and the plaintiffs injuries or damages

were proximately caused by the breach of that duty." Radley v. Fish, 2004 ME 87, ~ 12, 856

A.2d 1196 (internal citation and quotation marks omitted). Whether a defendant owed the

plaintiff a duty of care is a legal question decided by the court. Brown v. Delta Tau Delta, 2015

ME 75, ~ 9, 118 A. 3d 789. The existence of a duty is fact specific, and the facts of a given case

determine whether a defendant owed a duty of care to the plaintiff. Id.

A possessor ofland owes persons lawfully on the property a duty to use reasonable care.

Hankard v. Beal, 543 A.2d 1376, 1378 (Me. 1988). When a tenant assumes exclusive possession

and control of a property, "the tenant becomes like the owner of the property for most

purposes." Stewart v. Aldrich, 2002 ME 16, ~ 14, 788 A.2d 603. Thus, a landlord is generally

not liable for injuries caused by a dangerous condition that came into being after a tenant takes exclusive possession and control of a property. Id. ~ 10. However, a landlord is deemed to

retain control over the common areas of a leased property and may be liable for injuries caused

by a dangerous condition in those areas. Chiu v. City of Portland, 2002 ME 8, ~ 11, 788 A.2d

183.

While the plaintiff generally must establish facts supporting a pnma facie case of

negligence, the absence of control is an essential element that the landlord must establish in

order to avoid liability. 1 Id. ~ 12. "Control" in this context means "power over the property

that the landlord reserves pursuant to the terms of the lease or the tenancy, whether express or

implied, and does not include the incidental control that comes from being able to threaten

tenants with nonrenewal of a lease or with eviction." Stewart, 2002 ME 16, ~ 13, 788 A.2d 603.

B. Standard of Review

Summary judgment is appropriate if, based on the parties' statements of material fact

and the cited record, there is no genuine issue of material fact and the moving party is entitled

to judgment as a matter oflaw. M.R. Civ. P. 56( c); Dyer v. Dep't ifTransp., 2008 ME 106, ~ 14,

951 A.2d 821. "A material fact is one that can affect the outcome of the case. A genuine issue of

material fact exists when the fact finder must choose between competing versions of the truth."

Dyer, 2008 ME 106, ~ 14, 951 A.2d 821 (internal citation and quotation marks omitted). When

deciding a motion for summary judgment, the court reviews the evidence in the light most

favorable to the non-moving party. Id.

There are also three exceptions under which landlord may still be held liable for a dangerous condition on property under the exclusive control of a tenant: (a) when the landlord fails to disclose the existence of a latent defect which the landlord knew or should have known existed, but is not known to the tenant nor discoverable with reasonable care; (b) when the landlord gratuitously makes negligent repairs to the property; or (c) when the landlord expressly agrees to maintain the property in good repair. Stewart, 2002 ME 16, ~ 10, 788 A.2d 603 (internal citation omitted). Generally, in order to avoid liability, a landlord must also show that none of the enumerated exceptions applies. Id. ~ 12. Plaintiff, in her opposition, does not contend that any of these enumerated exceptions applies in this case. As noted above, Ginn bears the burden of proving that, as landlord, it has not exercised

or retained control over the property and thus is not liable to Plaintiff. When the party moving

for summary judgment bears the burden of persuasion on a claim or defense, the moving party

must establish the existence of each element of the claim or defense without dispute as to any

material fact in the record in order to obtain summary judgment. Cach, LLC v. Kulas, 2011 ME

70, ~ 9, 21 A.3d 1015. When a motion for summary judgment is properly supported, the

burden shifts to the non-moving party to respond with specific facts indicating a genuine issue

for trial in order to avoid summary judgment. M.R. Civ. P. 56(e). The evidence offered by the

non-moving party to establish a dispute of material fact "need not be persuasive at that stage,

but the evidence must be sufficient to allow a fact-finder to make a factual determination

without speculating." Estate of Smith v. Cumberland County, 2013 ME 13, ~ 19, 60 A.3d 7 59.

C. Ginn's Motion for Summary Judgment

The threshold issue raised by Ginn's motion is whether Ginn has met its initial burden

to establish that it does not exercise or retain control over its property. Only if Ginn has met

its burden does the focus shift to whether Albee has effectively controverted Ginn's showing by

generating a genuine issue of material fact that precludes summary judgment.

In support of its motion for summary judgment, Ginn contends that, under the terms of

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Related

Dyer v. Department of Transportation
2008 ME 106 (Supreme Judicial Court of Maine, 2008)
Hankard v. Beal
543 A.2d 1376 (Supreme Judicial Court of Maine, 1988)
Stewart Ex Rel. Stewart v. Aldrich
2002 ME 16 (Supreme Judicial Court of Maine, 2002)
Sung Ying Chiu v. City of Portland
2002 ME 8 (Supreme Judicial Court of Maine, 2002)
CACH, LLC v. Kulas
2011 ME 70 (Supreme Judicial Court of Maine, 2011)
Estate of Patrick P. Smith v. Cumberland County
2013 ME 13 (Supreme Judicial Court of Maine, 2013)
Elizabeth Brown v. Delta Tau Delta
2015 ME 75 (Supreme Judicial Court of Maine, 2015)
Radley v. Fish
2004 ME 87 (Supreme Judicial Court of Maine, 2004)

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Albee v. Trott, Counsel Stack Legal Research, https://law.counselstack.com/opinion/albee-v-trott-mesuperct-2015.