Engineering Dynamics, Inc. v. Rudman & Winchell, LLC

CourtSuperior Court of Maine
DecidedFebruary 18, 2020
DocketPENcv-16-99
StatusUnpublished

This text of Engineering Dynamics, Inc. v. Rudman & Winchell, LLC (Engineering Dynamics, Inc. v. Rudman & Winchell, 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
Engineering Dynamics, Inc. v. Rudman & Winchell, LLC, (Me. Super. Ct. 2020).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, ss. CIVIL DIVISION DKT. NO. CV-16-99 ENGINEERING DYNAMICS, INC., ) Plaintiff, ) ) v. ) JUDGMENT ) RUDMAN & WINCHELL, LLC and ) JOHN K. HAMER, ) Defendants. )

This is an attorney negligence action. Plaintiff Engineering Dynamics, Inc., holds the rights

to petition for and receive property tax abatements from the Town of Cushing for the April 1, 2005

tax year for two subdivisions (Meduncook Plantation and Gaunt Neck) that were being developed in

Cushing. 1 After failing to persuade the Town to grant the tax abatements in full, Plaintiff appealed

the denial to the State Board of Property Tax Review (the Board). The appeal concerned 6 lots in

Meduncook Plantation and 14 lots in Gaunt Neck. The Board received a substantial amount of

testimony over 9 days spread out over 20 months. In order to meet its burden before the Board,

Plaintiff offered the testimony of and appraisal by Norman Gosline, who was a real estate appraiser,

consultant, and broker.2 Mr. Gosline attempted to demonstrate (1) that Plaintiffs properties were

treated unequally in relation to other properties within Cushing, and (2) that the properties were

overvalued by the assessment. He offered both an assessment ratio study and an appraisal that relied

1 The entities that instituted the tax abatement proceedings in 2005 were Cushing Holdings, LLC (CH) and

Last Resort Holdings, LLC (LRH). James Tower was the sole owner of each entity. (R. Ex. 1, 2:5-15 (Apr. 14, 2008).) He also owned Engineering Dynamics. (R. Ex. 1, 24:20-21 (Apr. 14, 2008).) Before the State Board of Property Tax Review issued its decision on CH and LRH's appeal of the denial of the abatements, CH and LRH administratively dissolved. (Pl.'s Comp!. ,r 11.) CH andLRH-who had received the rights from Machias Savings Bank (R. Ex. 12, Petitioner's Ex. 33 before the Board.)-assigned the rights to petition for and receive property tax abatements regarding the 2005 tax abatement proceedings to Plaintiff. (Pl.'s Comp!. ,r 12.) The Court will simply reference "Plaintiff' in this order for the sake of simplicity. Additionally, there was a third subdivision being developed by Mr. Tower called Hornbarn Hill, but there were no lots in that subdivision subject to the appeal. The record did, however, contain information about Hombam Hill because it was located near and being developed at the same time as Meduncook Plantation and Gaunt Neck.

2 Mr. Gosline passed away while the present attorney negligence case was pending for trial.

1 on the "subdivision development method." In the formal written decision that the Board issued on

May 4, 2010, it rejected Mr. Gosline's testimony and appraisal as not credible evidence of just value.

The Board therefore concluded that Plaintiff had not met its burden before the Board and denied

Plaintiff's appeal.

Plaintiff then retained Defendants to pursue an SOC appeal to the Superior Court. Defendants'

attempted appeal of the Board's decision was dismissed by the Superior Court for lack of jurisdiction

due to the petition being filed one day beyond the statutory deadline. See generally Mt1tty v. Dep 't ef Con:,

2017 ME 7, ,r 8, 153 A.3d 775 (citations and quotation marks omitted) ("The time limits set forth in

the Administrative Procedure Act (APA) are jurisdictional, meaning that unless the petition is timely

filed, the court lacks jurisdiction."). Plaintiff then filed the pending action in June 2016.

The parties appeared for a bench trial on July 26, 2019, where the issue of the causation prong

of the negligence claim was argued. Plaintiff was represented by Jed Davis, Esq., and Defendants

were represented by John Whitman, Esq. The Court has reviewed the Board's record and considered

the arguments presented by each side in their respective trial briefs. It now issues this decision.

LEGAL STANDARD

"To prove attorney malpractice, a plaintiff must show (1) a breach by the defendant of the

duty owed to the plaintiff to conform to a certain standard of conduct; and (2) that the breach of that

duty proximately caused an injury or loss to the plaintiff." Pawlendzjo v. Haddow, 2016 ME 144, if 10,

148 A.3d 713. A showing of proximate cause is necessary to succeed on a legal malpractice claim, and

that requires introducing "evidence and inferences that may reasonably be drawn from the evidence

indicat[ing] that the negligence played a substantial part in bringing about or actually causing the injury

or damage and that the injury or damage was either a direct result or a reasonably foreseeable

consequence of the negligence." Mmiam v. Wanget; 2000 ME 159, ,r 8, 757 A.2d 778.

Generally, "a plaintiff must demonstrate that he or she would have achieved a more favorable

2 result but for the defendant's alleged legal malpractice." Nieheff v. Shank111an & Assocs. Legal Ct,:, PA.,

2000 ME 214, ,r 9, 763 A.2d 121. "A 'mere possibility' of a more favorable result is insufficient .... "

Bmoks v. Le111iet1x, 2017 ME 55, ,r 10, 157 A.3d 798. When the alleged legal malpractice stems from a

failure to perfect an appeal, "whether an appeal not taken would have succeeded is within the exclusive

province of the court, not the jury .... " Steeves v. Bemstcin, Sht1r, Sawyer & Nelson, P.C., 1998 ME 210,

,r 15, 718 A.2d 186 (citations and quotation marks omitted). The issue here then becomes whether Plaintiff would have received a better outcome had the

Rule SOC appeal been filed on time. Malcing this determination requires a counterfactual analysis of

the "case within the case." In other words, what was the likelihood that Plaintiff would have received

a better outcome with respect to the requested abatements if the Rule SOC appeal had been filed on

time? Would the Superior Court have vacated the Board's decision and remanded the case back to

the Board to engage in an independent determination of fair market value? If the Superior Court did

vacate and remand, after conducting this hypothetical independent determination of fair market value,

would the Board have granted the requested abatements? This requires a dive into the law on tax

abatement requests and appeals of denials of such requests.

When a taxpayer appeals the denial of an abatement to the Board it has to overcome the

presumption that the assessor's valuation is valid. Yt1se111 v. Town ojRay111ond, 2001 ME 61, ,r 8, 769

A.2d 865. In order to overcome this presumption of validity, the taxpayer must meet an initial burden

by proving to the Board that the assessment is manifestly wrong by showing that "(1) the judgment

of the assessor was irrational or so unreasonable in light of the circumstances that the property was

substantially ove1valued and an injustice resulted; (2) there was unjust discrimination; or (3) the

assessment was fraudulent, dishonest, or illegal." Id ,r 9. Merely impeaching the assessor's

methodology is not sufficient to show that the assessment is manifestly wrong. Id ,r 13. Instead,

when the taxpayer attempts to meet its initial burden to show that the assessor substantially overvalued

3 the property, the taxpayer must present the Board with credible evidence of its view of just value to

demonstrate the assessment is manifestly wrong. Id. ,r 8.

"If, but only if, the taxpayer meets that burden, the [Board] must engage in an independent

determination of fair market value ... based on a consideration of all relevant evidence of just value."

Id.

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Related

Steeves v. Bernstein, Shur, Sawyer & Nelson, P.C.
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Town of Southwest Harbor v. Harwood
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Niehoff v. Shankman & Associates Legal Center, P.A.
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Merriam v. Wanger
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Wesson v. Town of Bremen
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Emery v. Woodward
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Thomas M. Brooks v. John R. Lemieux
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Engineering Dynamics, Inc. v. Rudman & Winchell, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/engineering-dynamics-inc-v-rudman-winchell-llc-mesuperct-2020.