Baratta Realty Co. v. Brandano

32 Mass. App. Dec. 21
CourtMassachusetts District Court, Appellate Division
DecidedJuly 1, 1968
DocketNo. 6029; No. 2656
StatusPublished

This text of 32 Mass. App. Dec. 21 (Baratta Realty Co. v. Brandano) is published on Counsel Stack Legal Research, covering Massachusetts District Court, Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baratta Realty Co. v. Brandano, 32 Mass. App. Dec. 21 (Mass. Ct. App. 1968).

Opinion

Connolly, J.

The facts in this action on a judgment are described in the “Findings and Rulings” of the trial judge which are as follows:

“Plaintiff owned real estate adjoining real estate in which defendants, John F. Zamparelli and Mary B. Held, had an interest. These two persons engaged defendant Brandano to do excavating on their property which resulted in damage to the adjoining property of plaintiff.
“Plaintiff sued all three of the foregoing in one tort action asserting that defendants, their agents or servants negligently caused to be made a deep excavation as the result of which plaintiff’s adjoining property was damaged. When the case came to trial only defendants Zamparelli and Held were present. Defendant Brandano was defaulted. Plaintiff recovered against defendants Zamparelli and Held by verdict of a jury in the amount of $1000. Judgment was entered against the two defendants in the sum of $1,118.26 without costs. An execution issued against them in the above amount and the execution was satisfied.
“Sometime later, judgment having been entered against defendant Brandano on default, damages were assessed against him [23]*23by a judge of the Superior Court in the amount of $6,coo to which were added interest and costs totaling $6,780.34. Plaintiff, having obtained an execution for that amount, is now suing on that judgment. “The Brandano defense is that the three defendants were joint tortfeasors and that satisfaction of the judgment and execution in the other two cases bars any further recovery against Brandano.
“There is no clue as to whether the assessing judge knew of the previous verdicts and payments satisfying the execution against Zamparelli and Held nor as to his basis of calculating the amount of his finding. It seems clear that the parties were joint tortfeasors and that had all three defendants appeared for trial, the judgment would have had to be the same against all.
“On the other hand, here is an unsatisfied execution for $6,780.34 issued by the Superior Court. The question, therefore, is whether this District Court is compelled to recognize that execution and find in favor of plaintiff in the above amount or whether this court may hold, as a matter of law, that the satisfaction of the execution against Zamparelli and Held relieved defendant Brandano from further payment? “Argument was offered that the Superior Court judge may for good reason have found that there was special and greater liability on defendant Brandano because he and his company were the ones who [24]*24actually caused the damage. The argument does not seem to me to hold water. Brandano was working for Zamparelli and Held just as the chauffeur of an automobile is serving his employer when he drives him around in his car. Both in the eyes of the law are liable in an equal amount in case of accident. That one joint tortfeasor may have greater responsibility for the accident is not ground for. differentiating between the two when it comes to damages.
“On the other hand it can be argued that there is outstanding and unsatisfied an execution issued by the Superior Court which this court cannot go behind and must enforce. In support of this contention, it can be said that by defaulting in the first instance, and in the second instance when damages were assessed by failure then or duly thereafter to take appropriate steps to rectify what counsel now asserts to have been an improper assessment, Brandano has been guilty of loches and is estopped to take advantage of an otherwise valid defense.
“It is a close question. On the whole, I am not inclined to go behind the judgment and execution issued against defendant Brandano, although the assessment in Superior Court may have been inconsistent with the law of joint tortfeasor liability. The place to correct that inconsistency was in the court where the assessment occurred. The defendant has in effect been guilty of loches. [25]*25He had three opportunities to protect himself—first, when he failed to appear in the original suit and was defaulted. Again, when he failed to appear at the hearing on the assessment and once more after notice of the assessment itself.
“I find for the amount of the execution against defendant Brandano less the amount of the first execution against Zamparelli and Held in view of plaintiff conceding that this deduction is equitable under all of the circumstances.”

The defendant filed a number of requests for rulings including the following:

No. 17. A release of one of several joint tortfeasors operates to discharge all. Matheson v. O’Kane, 211 Mass. 93.

No. 18. A satisfaction of judgment against John F. Zamparelli and Mary B. Held, or either of them, in said Middlesex Superior Court .case number 227192 acts as a discharge or release of John A. Brandano a/k/a, and the judgment and execution which issued against him in said Middlesex Superior Court case number 227192.

No. 19. A satisfaction from one discharges all, as the plaintiff has only a single cause of action and is entitled but to one satisfaction in damages. Matheson v. O’Kane, [26]*26supra; Brewer v. Casey, 196 Mass. 384.

No. 20. A release or satisfaction of judgment against one or more which discharges the liability of one joint tortfeasor released the others, since their liability is one and indivisible and is necessarily destroyed by the discharge of one. Matheson v. O’Kane, supra.

The trial judge disposed of these requests in this manner: “No. 17-20 granted as a general statement of law but not applicable to this .case.”

We think this was prejudicial error; that the requests were applicable to this case; that the satisfaction of one judgment was the legal equivalent of payment of the other and the fact that an execution had issued on the other (the judgment in suit) would not affect its status.

We quote from “Restatement of the law of Judgments” section 95-b (emphasis added). “The discharge of a judgment against any one of several persons liable for a single harm or breach of duty, owed by all, discharges the others except for costs in actions begun against the others. Likewise, a payment in full by or on behalf of one of the judgment debtors which is accepted by the judgment creditor discharges the others except for costs. This is true where no judgment has been obtained against the [27]*27other obligors, where judgments have been obtained against the other obligors either for the same amount or for larger amounts in separate actions, and where judgments have been obtained against the others in the same action. It is immaterial whether the one paying was, with reference to the one who has not paid, primarily or secondly liable (see Restatement of Restitution §147(3) and Restatement of Torts §886).”

The satisfaction of one of two separate judgments obtained on the same demand or cause of action against different obligors discharges both. Thus, although separate judgments may be rendered against joint tortfeasors, there can be but one satisfaction. The general rule is that judgments against joint tortfeasors are deemed satisfied by satisfaction of a judgment against one of the joint tortfeasors.

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Bluebook (online)
32 Mass. App. Dec. 21, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baratta-realty-co-v-brandano-massdistctapp-1968.