Eastern Maine Electric Cooperative, Inc. v. First Wind Holdings, LLC

CourtSuperior Court of Maine
DecidedApril 13, 2017
DocketCUMbcd-cv-15-048
StatusUnpublished

This text of Eastern Maine Electric Cooperative, Inc. v. First Wind Holdings, LLC (Eastern Maine Electric Cooperative, Inc. v. First Wind Holdings, LLC) 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
Eastern Maine Electric Cooperative, Inc. v. First Wind Holdings, LLC, (Me. Super. Ct. 2017).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT CUMBERLAND, SS. DOCKET NO. BCD-CV~lS-048 ../

EASTERN MAINE ELECTRIC ) COOPERATIVE, INC., ) ) Plaintiff, ) ) v. ) COMBINED ORDER ON PARTIES' ) POST-TRIAL MOTIONS FIRST WIND HOLDINGS, LLC, et al., ) ) Defendants. )

Before the Court are the following post-trial motions: (1) Defendants First Wind

Holdings, LLC ("First Wind"), Evergreen Gen Lead, LLC, Evergreen Wind Powe1· III, LLC,

Stetson Holdings, LLC, and Stetson Wind II, LLC's (collectively uDefendants") renewed motion

for judgment as a matter of law, or, in the altemative, tnotion for a new trial or remittitur; (2)

Plaintiff Eastern Maine Electric Cooperative, Inc. 's ("EMEC") motion for immediate execution

or alternatively, an order that Defendants give a bond pending appeal; and (3) EMEC's bill of

costs.

On December 23, 2011, EMEC, First Wind, on behalf of itself and any subsidiaries in

involved in the transaction, and Bangor Hydro Electric Company ("Bangor Hydro" or "BHE")

and its parent company Emera, Inc. ("Emera") entered into a Precedent Transmission Line

Agreement (the "Precedent Agreement''). The Precedent Agreement incorporated a Te1m Sheet,

which set forth certain terms for the sale of a transmission line lmow11 as the "Stetson Linen to

EMEC and Bangor Hydro. The parties agree that the Precedent Agreement required them to

negotiate in good faith to come a definitive agreement regarding the sale of the Stetson Line.

The parties were ultimately unable to reach a definitive agreement. EMEC filed a complaint with the Superior Court on October 24, 2014. This action was then transferred to the Business

and Consumer Docket. On November 18, 2016, a Penobscot County jury returned a verdict

awarding damages to EMEC in the amount of $13)604,400.00 in lost profits. On November 21,

2016, the court entered judgment against Defendants.

Oral argument on all pending motions was held on January 31, 2017. The court

considered the parties' written submission, the last of which was received on March 10, 2017, It

has also reviewed its notes from trial as well as ce1tain transcripts of witness testimony. For the

reasons stated below, the court denies Defendants' renewed motion for judgment as a matter of

law, Defendants' motion for a new trial or remittitur, and EMEC's motion for immediate

execution or that Defendants give a bond pending appeal. The court defers consideration of

EMEC's bill of costs pending the expiration of the appeal period or the conclusion on any appeal

to the Law Court.

I. DEFENDANTS' MOTION FOR JUDGMENT AS A MATTER OF LAW

A. Standard of Review.

Pursuant to Maine Rule of Civil Procedul'e 50(a), the court may grant a motion for

judgment as a matte1· of law if "viewing the evidence and all reasonable inferences therefrom

most favorably to the party opposing the motion, a jury could not reasonably find for that party

on an issue that under the substantive law is an essential element of the claim." M.R. Civ. P.

SO(a), A party seeking judgment as a matter of law pursuant to Rule 50(b) following a trial must

establish that "the adverse jury verdict was 'clearly and manifestly wrong.'" Me. Energy

Recove,y Co. v. United Steel Structures, Inc., 1999 ME 31 1 1 5, 724 A.2d 1248 (citation

omitted); M.R. Civ. P, 50(b). The comt shall grant a motion for judgment as a matter of law

following a trial "only if the jury was 'rationally compelled' to conclude that the m~ving party is

2 entitled to judgment in its favor, and should deny the motion if 'based on all the evidence,

reasonable minds could reach different conclusions on dispositive questions of fact."' Tobin v.

Barter, 2014 ME 51, ~ 8, 89 A.3d 1088 (citation omitted). In other words, a motion for

judgment as a matter of law will not be granted Hif any reasonable view of the evidence could

sustain a verdict for the opposing party.'' Id (internal quotation and citation omitted).

To prevail on a breach of contract claim, a plaintiff must establish: (1) the parties had a

legally binding contract; (2) the defendant breached a material te1·m of the contract; and (3)

defendant's breach caused the plaintiff to suffer damages, Id ~,r 9-10. Whether a party has

breached a material term of a contract and causation are questions of fact for the jury. Me.

Energy Recovery Co., 1999ME31 1 17, 724 A.2d 1248.

An agreement to negotiate in good faith toward the formation of another contract can

itself be an enforceable contract so long as the agreement to negotiate in good faith otherwise

meets the requirements to form a binding contract. Venture Assocs. Corp. v. Zenith Data Sys.

Corp., 96 F.3d 275, 277 (7th Cir. 1996). "Good faith" requires both honesty in fact and that the

party observes reasonable commercial standards of fair dealing. Darling's v. Ford Motor Co.,

1998 ME 232, ,r 14, 719 A.2d 111. In order to obtain an award of damages for the benefit of the

bargain, the plaintiff must prove that one or more defendants acted in bad faith; that _but for the

bad faith, the pa1ties would have reached a final agreement; that the loss of the final agreement

was a foreseeable result of the bad faith; and the damages must be proven to a reasonable degree

of certainty. Venture Assocs. Co,p., 96 F.3d at 278; Restatement (Second) of Contracts§§ 347,

351 -52.

3 B. Analysis

Defendants assert they are entitled to judgment as a matter of law on five grounds: (1)

there was insufficient evidence that Defendants failed to negotiate in good faith; (2) there was no

evidence that parties could have obtained lender consent; (3) there was insufficient evidence of

mutual assent to the tenns of the Tenn Sheet; (4) the Precedent Agreement provided the sole

remedy in the event a definitive agreement was not reached and lost profits were not reasonably

foreseeable; and (5) there was insufficient evidence to find the Subsidiary Defendants liable.

(Defs. Mot. 3-15.) The court addresses each issue in tl.U'n.

1. Obligation to Negotiate in Good Fafth

Defendants assert that no reasonable jm-y could find that Defendants breached their

obligation to negotiate in good faith toward a definitive trnnsmission line agreement to sell the

Stetson Line. (Id at 3-5.) Defendants assert that 'the trial recol'd was completely devoid of any

evide~ce of dishonesty, improper tactics or deliberate misconduct" that would rise to the level of

bad faith. (Id. at 5.) Defendants assert, rather, there was substantial evidence that First Wind

worked diligently in negotiating towards a definitive agreement. (Id at 5-6.) Defendants also

argue that the Precedent Agreement required that all "reasonable and c'l.1stomary terms 11 would be

included in the final agreement and that the evidence at trial showed that insurance was a

"reasonable and customary term.,' (Id. at 6.) In response, EMEC asserts that the jury could have

found that Defendants failed to meet their obligation to negotiate in good faith in at least two

ways: (1) Defendants demanded that EMEC obtain property insurance for the Stetson Line, an

impossible task because such insurance does not exist; and (2) Defendants' demand that EMEC

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

Related

Dyer v. Department of Transportation
2008 ME 106 (Supreme Judicial Court of Maine, 2008)
Pelletier v. Fort Kent Golf Club
662 A.2d 220 (Supreme Judicial Court of Maine, 1995)
Darling's v. Ford Motor Co.
1998 ME 232 (Supreme Judicial Court of Maine, 1998)
Maine Energy Recovery Co. v. United Steel Structures, Inc.
1999 ME 31 (Supreme Judicial Court of Maine, 1999)
Rutland v. Mullen
2002 ME 98 (Supreme Judicial Court of Maine, 2002)
Garland v. Roy
2009 ME 86 (Supreme Judicial Court of Maine, 2009)
Town of Lisbon v. Thayer Corp.
675 A.2d 514 (Supreme Judicial Court of Maine, 1996)
Pettengill v. Turo
193 A.2d 367 (Supreme Judicial Court of Maine, 1963)
Watt v. UniFirst Corp.
2009 ME 47 (Supreme Judicial Court of Maine, 2009)
Maine Eye Care Associates P.A. v. Gorman
2008 ME 36 (Supreme Judicial Court of Maine, 2008)
Villas by the Sea Owners Ass'n v. Garrity
2000 ME 48 (Supreme Judicial Court of Maine, 2000)
Flaherty v. Muther
2011 ME 34 (Supreme Judicial Court of Maine, 2011)
Flaherty v. Muther
2011 ME 32 (Supreme Judicial Court of Maine, 2011)
Philip C. Tobin v. Philip N. Barter
2014 ME 51 (Supreme Judicial Court of Maine, 2014)
Estate of Michael Lewis v. Concord General Mutual Insurance Company
2014 ME 34 (Supreme Judicial Court of Maine, 2014)
John McClare v. James J. Rocha
2014 ME 4 (Supreme Judicial Court of Maine, 2014)
Monica L. Semian v. Ledgemere Transportation, Inc.
2014 ME 141 (Supreme Judicial Court of Maine, 2014)
Mark Chartier v. Farm Family Life Insurance Co.
2015 ME 29 (Supreme Judicial Court of Maine, 2015)
Ford Motor Company v. Darling's
2016 ME 171 (Supreme Judicial Court of Maine, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Eastern Maine Electric Cooperative, Inc. v. First Wind Holdings, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eastern-maine-electric-cooperative-inc-v-first-wind-holdings-llc-mesuperct-2017.