Chludzinski v. Scott

CourtSuperior Court of Maine
DecidedNovember 4, 2021
DocketCUMre-21-21
StatusUnpublished

This text of Chludzinski v. Scott (Chludzinski v. Scott) 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
Chludzinski v. Scott, (Me. Super. Ct. 2021).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. RE-21-21

MICHAEL CHLUDZINSKI, et al.,

Plaintiffs V. ORDER

ZOE SCOTT, et al.,

Defendants

Before the court is third-party defendant Donn Storey's motion to dismiss Count

Four (negligent misrepresentation) and Count Six (fraud) of the third-party complaint filed

against him by defendants Zoe Scott and Michael Falby.

Plaintiffs Michael and Christina Chludzinski commenced this action by filing a

complaint against Scott, Falby and a third defendant, Steven Colby, asserting a claim

pursuant to 14 M.R.S. § 7552 for cutting down trees and disturbing soils on the

Chludzinskis' property in Casco. Scott and Falby had purchased property in the vicinity of

the Chludzinskis' property and had hired Colby to clear a portion of the land for a house

site. Colby is alleged, as an agent for Scott and Falby, to have wrongly cut down trees and

disturbed soil on the Chludzinskis' property.

Various counterclaims and cross-claims have been filed. As relevant to the instant

motion, Scott and Falby filed a third-party complaint against Storey, from whom they had

purchased their property. In the their third-party complaint they allege that Gloria Hewey,

a realtor acting as Storey's agent, had provided them with inaccurate and false information

with respect to the location of the property they purchased. 1

1 Scott and Falby only named Storey, and not Hewey, in their third-party complaint. Once he was

sued by Scott and Falby, however, Storey filed a third -party complaint against Hewey. REC'D CUMB CLERKS OF NOV 5 '21 AM8:19 Standard of Review

For purposes of a motion to dismiss, the material allegations of a third-party

complaint must be taken as admitted. Ramsey v. Baxter Title Co., 2012 ME 113 ii 2, 54 A.3d

710. The third-party complaint must be read in the light most favorable to the third-party

plaintiff to determine if it sets forth elements of a cause of action or alleges facts that would

entitle the third-party plaintiff to relief pursuant to some legal theory. Bisson v. Hannaford

Bros. Co., Inc., 2006 ME 131 ,r 2, 909 A.2d 1010. Dismissal is appropriate only when it

appears beyond doubt that the third-party plaintiff is not entitled to relief under any set of

facts that he might prove in support of his claim. Moody v. State Liquor & Lottery

Commission, 2004 ME 20 ,r 7, 843 A.2d 43. However, the third-party complaint should be

dismissed if it fails to allege essential elements of the cause of action. See Potter, ?reseat~

Jamieson & Nelson P.A. v. Campbell, 1998 ME 70 ,Tf 6-7, 708 A.2d 283.

A separate rule applies to allegations of fraud because M.R.Civ.P. 9(b) requires that

the circumstances allegedly constituting fraud must be stated with particularity.

Negligent Mis rep res en tation

Count Four of the Scott-Falby third-party complaint alleges a claim of negligent

misrepresentation:

One who, in the course of his business, profession or employment, or in any other transaction in which he has a pecuniary interest, supplies false information for the guidance of others in their business transactions, is subject to liability for pecuniary loss caused to them by their justifiable reliance upon the information, if he fails to exercise reasonable care or competence in obtaining or communicating the information.

Chapman v. Rideout, 568 A.2d 829,830 (Me. 1990), quoting Restatement (Second) of Torts § 552(1) (1977). A negligent misrepresentation claim is not subject to the heightened

pleading standard applicable to a fraud claim.

2 The third-party complaint alleges that Storey was the seller of property for which

he received $47,500 (demonstrating Storey's pecuniary interest), that Hewey as Storey's

agent 2 provided false information to Scott and Falby as to the location of the property

when they were purchasing the property, that Hewey as Storey's agent failed to exercise

reasonable care in providing the information in question, that Scott and Falby justifiably

relied on that information, and that as a result they incurred a pecuniary loss. Third-Party

Complaint ,-r,r 5-7, 10, 13-14, 17, 36, 53-56. This adequately states a claim for negligent

misrepresentation.

While the third-party complaint is somewhat equivocal on the issue of reliance ­

because it alleges that Scott and Falby sought to have their contractor confirm the location

information they had been given (Id. ,r 18) - the court cannot conclude from the allegations

of the third-party complaint that it is beyond doubt that they did not justifiably rely on the

allegedly false location information they had been given by Hewey.

Storey argues that the third-party complaint references communications that he

asserts occurred after the principal/agent relationship between Storey and Hewey had

ended, but this argument fails because the third-party complaint alleges that false

information was provided prior to Scott and Falby's purchase of the property, when Hewey

was acting as Storey's agent. Third-Party Complaint ,r,T 7-14.

Count Six of the Scott-Falby third-party complaint alleges that the allegedly false

information provided by Hewey as Storey's agent constituted fraud.

To assert a cognizable claim of fraud against Storey, Scott and Falby must allege that

(1) Storey, through his agent, made a false representation; (2) of a material fact; (3) with

knowledge of its falsity or in reckless disregard of whether it was true or false; (4) for the

2"Under Maine law a principal is liable for the fraudulent misrepresentations made by his agent within the scope of the agent's authority, whether or not the principal knows of the agent's misconduct." Arbour v. Hazelton, 534 A.2d 1303, 1306 (Me. 1987).

3 purpose of inducing Scott and Falby to act in reliance upon it; and (5) that Scott and Falby

justifiably relied upon the representation to their detriment. Barr v. Dyke, 2012 ME 108 ,r

16, 49 A.3d 1280 (citing Flaherty v. Muther, 2011 ME 32 ,r 45, 17 A.3d 640).

The additional requirement in M.R.Civ.P. 9(b) that the circumstances allegedly

constituting fraud must be stated with particularity requires, at a minimum, that the

specifics of the alleged misrepresentation be set forth so that the party against whom the

claim is made is "fairly apprised of the elements of the claim." 2 C. Harvey, Maine Civil

Practice§ 9:2 at 384 (3d ed. 2011).

In this case Scott and Falby have set forth the necessary elements of a fraud claim,

but the specifics of the alleged misrepresentation made by Hewey as Storey's agent have

not been set forth with sufficient particularity. A general allegation that false information

was provided as to the location of the property is insufficient. The third-party complaint

does not specify what specific information was false or allege what specific representations

were made as to the boundaries of the purchased property and how those representations

differ from the actual boundaries.

There are cases suggesting that the time, place, and content of a fraudulent

misrepresentation must be stated with particularity. In this case the third-party complaint

adequately apprises Storey that the allegedly fraudulent misrepresentation occurred at the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Arbour v. Hazelton
534 A.2d 1303 (Supreme Judicial Court of Maine, 1987)
Chapman v. Rideout
568 A.2d 829 (Supreme Judicial Court of Maine, 1990)
Bisson v. HANNAFORD BROTHERS COMPANY, INC.
2006 ME 131 (Supreme Judicial Court of Maine, 2006)
Potter, Prescott, Jamieson & Nelson, P.A. v. Campbell
1998 ME 70 (Supreme Judicial Court of Maine, 1998)
Flaherty v. Muther
2011 ME 32 (Supreme Judicial Court of Maine, 2011)
Ramsey v. Baxter Title Co.
2012 ME 113 (Supreme Judicial Court of Maine, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Chludzinski v. Scott, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chludzinski-v-scott-mesuperct-2021.