Bettinger v. Berman & Simmons

CourtSuperior Court of Maine
DecidedMay 8, 2015
DocketCUMcv-13-185
StatusUnpublished

This text of Bettinger v. Berman & Simmons (Bettinger v. Berman & Simmons) 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
Bettinger v. Berman & Simmons, (Me. Super. Ct. 2015).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss. CIVIL ACTION Docket No. CV-13-185

LESLIE BETTINGER,

Plaintiff v. ORDER

BERMAN & SIMMONS, P.A., STATE Of MAiNE,.._ Cunterland, sa, Cleft's UIIII.R Defendant MAY 08 2015

Before the court is a motion by defendant Berman & Simmons for recB~~~y;;p court's March 23, 2015 order denying summary judgment and denying in part defendant's

motion to exclude certain opinions ofplaintiffLeslie Bettinger's expert, Thomas Hallett.

Summary Judgment

Berman & Simmons argues that on summary judgment a plaintiff is obliged to offer

evidence establishing a prima facie case on each element of her cause of action. This obligation,

however, is not unlimited. A party opposing motion is not obliged to establish a prima facie case

for elements of the cause of action not challenged by the movant. See Corey v. Norman Hanson

& DeTroy, 1999 ME 196 ~ 9, 742 A.2d 933. Moreover, on summary judgment the court is

required to consider only the portions of the record referred to and the material facts set forth in

the parties' Rule 56(h) statements. E.g., Johnson v. McNeil, 2002 ME 99 ~ 8, 800 A.2d 702.

This means that if the movant's statement of material facts does not address an issue,

summary judgment cannot be granted on that issue. By way of example, the court found that

there is a disputed issue of fact as to whether Attorney Nofsinger breached the applicable

standard of care in her efforts to obtain a substitute expert based on alleged inaccuracies and omissions in the information she provided to prospective substitutes. The statement of material

facts submitted by Berman & Simmons did not assert that the alleged inaccuracies and omissions

would not have affected the substitute experts' opinions. Accordingly, Bettinger was not required

to offer evidence on that issue.

The court separately ruled that Attorney Hallett cannot offer speculation that, absent

Nofsinger's alleged inaccuracies and omissions, the proposed substitute experts she consulted

would have changed their opinions. Where that leaves the parties is (1) that summary judgment

has been denied on this issue but (2) that to prove that any alleged malpractice by Nofsinger in

communicating with proposed substitute experts was a legal cause of injury, Bettinger will have

to offer evidence other than speculation by Hallett. 1

Another issue on which Bettinger has faulted Berman & Simmons relates to Nofsinger's

failure to seek an extension beyond January 15, 2008 in which to designate a substitute expert.

However, the statement of material facts filed by Berman & Simmons did not assert that there is

no evidence other than the opinion offered by Hallett that an extension, if requested, would have

been granted. Accordingly, summary judgment cannot be entered based on any failure by

Bettinger to offer admissible evidence on that issue.

In its March 23 order the court ruled that any opinion by Hallett that an extension would

likely have been granted would be impermissibly speculative. Assuming Bettinger cannot prove

this in some other fashion - and the court is not currently aware of any other proof that could be

1 In her opposition to the motion for reconsideration, Bettinger appears to contend that she can do this by offering evidence from a different doctor that the information in question would have affected his opinion. The court expresses no opinion as to whether this would be admissible to prove that the experts consulted by Nofsinger would have changed their views. That is an issue which will have to be decided after further elaboration on a motion in limine or at trial. However, the court adheres to its ruling that Hallett cannot offer an opinion as to whether medical experts would have changed their opinions if Nofsinger had provided them with other information.

2 offered- this will mean that, to the extent that Bettinger's claim against Berman & Simmons is

based on the failure to seek an extension, that claim will fail at trial. For purposes of summary

judgment, however, the court is limited to the statements of material facts, and the statement of

material facts submitted by Berman & Simmons did not require Bettinger to controvert this . 2 ISSUe.

Although Berman & Simmons's motion to exclude Hallett's opinions was combined for

oral argument with its motion for summary judgment, those motions were filed and briefed

separately. Berman & Simmons is now arguing, in effect, that the only evidence of causation on

certain issues consists of opinions by Hallett which are subject to exclusion. That may be true but

Bettinger has not made that concession, and unless that issue was raised in the summary

judgment papers, the court cannot make that assumption.

This ruling can be characterized as a mechanistic application of the summary judgment

rules. However, in the court's view, the summary judgment rules - and in particular the

limitation of the summary judgment record to the citations and assertions in the parties'

respective statements of material facts - are intended to be mechanistic. Unless rulings on

summary judgment are tied to the specific assertions and denials in the parties' Rule 56(h)

statements, the court would be left with the task of searching through a record that in this case

consists of voluminous deposition transcripts and exhibits. The Law Court has ruled that this is

not required or permissible. Levine v. R.B.K. Caly Corp., 2001 ME 77 ~ 9, 770 A.2d 653.

2 The court does not agree with plaintiff that her conclusory statements that the alleged breaches of duty caused her harm, see Plaintiffs Additional Statement of Material Facts ~~ 67-68, would be sufficient to preclude summary judgment if the statement of material facts submitted by Berman & Simmons had required plaintiff to offer specific admissible evidence that either the alleged inaccuracies and omissions in the information sent to substitute experts or Nofsinger's failure to seek an extension of the January 15, 2008 deadline would likely have affected the outcome of the case.

3 Finally, the court adheres to the view that Bettinger has offered sufficient evidence to

generate a factual dispute for trial with respect to whether Nofsinger's alleged agreement with

Attorney Lavoie and her alleged lack of enthusiasm for Bettinger's case amounted to a breach of

the standard of care and resulted in harm to Bettinger.

Exclusion of Expert Opinions

In its March 23, 2015 order the court excluded certain opinions offered by Hallett but did

not exclude others.

In its order the court noted that while Berman & Simmons argued that certain of Hallett's

opinions should be excluded as being contrary to the facts, that is ordinarily an issue for trial.

Berman & Simmons points out that an expert's opinion should be excluded when there is no

evidence to support it, citing Green v. Cessna Aircraft Co., 673 A.2d 216, 218-19 (Me. 1996).

This is correct if there is no dispute as to the facts or if the court can find no evidence to support

the opinion in question.

With respect to the opinions that the court did not exclude as being contrary to the facts,

see March 23, 2015 order at 5 n.2, the court concluded that there was an underlying factual

dispute and it was unable to conclude that there was no evidence to support Hallett's opinions.

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Related

Johnson v. McNeil
2002 ME 99 (Supreme Judicial Court of Maine, 2002)
Green v. Cessna Aircraft Co.
673 A.2d 216 (Supreme Judicial Court of Maine, 1996)
Corey v. Norman, Hanson & DeTroy
1999 ME 196 (Supreme Judicial Court of Maine, 1999)
Rodrigue v. Rodrigue
1997 ME 99 (Supreme Judicial Court of Maine, 1997)
Levine v. R.B.K. Caly Corp.
2001 ME 77 (Supreme Judicial Court of Maine, 2001)

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