Fuschetti v. Murray

2006 ME 100, 903 A.2d 848, 2006 Me. LEXIS 117
CourtSupreme Judicial Court of Maine
DecidedAugust 16, 2006
StatusPublished
Cited by9 cases

This text of 2006 ME 100 (Fuschetti v. Murray) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fuschetti v. Murray, 2006 ME 100, 903 A.2d 848, 2006 Me. LEXIS 117 (Me. 2006).

Opinion

DANA, J.

[¶ 1] Rosalie Fuschetti appeals from a judgment entered in the Superior Court (Cumberland County, Warren, J.) ordering John P. Murray to pay statutory and common law damages for trees he cut down on her property. She argues that the court erred in concluding that the cost for replanting and restoring the trees is not an appropriate measure of damages pursuant to 14 M.R.S. § 7552(3) (2005). Murray cross-appeals, arguing that the court erred *849 in awarding both statutory and common law damages for the same injury. Because we disagree with Fuschetti, and agree with Murray, we vacate and remand to the Superior Court for recalculation of costs.

I. BACKGROUND

[¶ 2] The facts are undisputed. In the spring of 2002, Murray, in order to improve his view, cut down and damaged trees on Fuschetti’s property. Later that year, Fuschetti’s lawyer sent Murray a letter indicating that Fuschetti would be commencing an action against Murray pursuant to 14 M.R.S. § 7552 (2005). 1 Thereafter, the State also brought an action against Murray pursuant to 17 M.R.S. § 2510 (2005), 2 and, in partial resolution of the State’s action, Murray was required to *850 pay, and paid, $5306 in restitution to Fus-chetti.

[¶ 3] In January 2004, Fuschetti filed her complaint seeking damages pursuant to 14 M.R.S. § 7552. Previously, Murray had made a $6500 offer of judgment in Fuschetti’s promised private action, which Fuschetti rejected. After discovery, Murray moved for summary judgment, which the court denied. At the same time, Fus-chetti and Murray each moved to exclude the other’s expert testimony. The motions were directed to the issue of the appropriate measure of damages pursuant to 14 M.R.S. § 7552. As a result, the court determined that the costs for replanting and restoring the trees on Fuschetti’s property were not an appropriate measure of damages pursuant to 14 M.R.S. § 7552(3). The court concluded, however, that Fuschetti could potentially recover those costs at common law, and suggested that Fuschetti amend her complaint to add a common law trespass claim. Fuschetti did so, and the case proceeded to a jury trial on both the common law and statutory trespass claims.

[¶ 4] The parties stipulated that Murray committed a trespass and destroyed or damaged trees on Fuschetti’s property. They also agreed on the number and diameters of the trees that Murray had wrongfully cut down, for the purpose of calculating forfeiture damages pursuant to 14 M.R.S. § 7552(3)(B) and 17 M.R.S. § 2510(2). Two issues remained for the jury: (1) whether Murray’s trespass was intentional or knowing (for the purpose of calculating damages pursuant to section 7552(4)); and (2) the amount of any restoration costs (for the purpose of measuring damages under the common law claim). The jury found that (1) Murray acted intentionally or knowingly; and (2) the restoration costs totaled $5306.

[¶ 5] In its post-trial order the court concluded that pursuant to 14 M.R.S. § 7552(3) “damages may be sought in the alternative for (l)[the] value of the lost trees (stumpage value), (2)[the] loss in the overall value of the property, or (3)[the] forfeiture value under 17 M.R.S. § 2510.” Because Fuschetti did not present any evidence at trial as to stumpage value or as to the loss in the overall value of the property, the court considered only the forfeiture value of the trees in its analysis of Fus-chetti’s statutory claim. Pursuant to section 7552(3)(B) and 17 M.R.S. § 2510(2), the court awarded Fuschetti forfeiture damages totaling $1075, which it trebled to $3225 pursuant to section 7552(4)(B), plus prejudgment interest of $193.50 and professional fees of $1709.25, for a total of $5127.75. The court concluded that under her common law trespass claim, Fuschetti was entitled to recover $5306 for replanting and restoring her trees. Overall, Fus-chetti was awarded $10,433.75, which was reduced by the $5306 Murray had already paid to Fuschetti as a result of the State action. 3 This left Fuschetti with a net recovery of $5127.75, less than she had been offered in the $6500 offer of judgment.

II. SECTION 7552 DAMAGES

[¶ 6] Fuschetti contends that the court erred in concluding that the costs of *851 replanting and restoring the property are not recoverable pursuant to 14 M.R.S. § 7552(3). Specifically, she argues that section 7552 does not limit the value of lost products to the stumpage value of the trees and should include the costs of replanting and restoring. She contends that our decisions in Stockly v. Doil, 2005 ME 47, 870 A.2d 1208; Morissette v. Somes, 2001 ME 152, 782 A.2d 764; and Leavitt v. Continental Telephone Co. of Maine, 559 A.2d 786 (Me.1989), support her position that replacement and restoration costs are recoverable as an element of damages pursuant to section 7552.

[¶ 7] These earlier cases are all distinguishable. In Stockly, the trial court found the defendant liable pursuant to section 7552 as well as 14 M.R.S. § 7552-A (2005), 4 but refused to consider evidence of the plaintiffs cleanup costs as an element of damages. 2005 ME 47, ¶¶ 1, 8-9, 24, 870 A.2d at 1209-11, 1215. We concluded that the defendant was not liable pursuant to section 7552, vacated the portion of the judgment based on that provision, and did not reach the question of whether restoration costs are available pursuant to section 7552. Id. ¶ 21, 870 A.2d at 1215. 5

[¶ 8] In Morissette, the trial court (1) determined that the defendant committed common law trespass when she stripped sod from the plaintiffs lawn; (2) awarded damages for the common law trespass claim based on the cost of resodding the lawn area; and (3) awarded treble damages pursuant to section 7552 for a tree that the defendant had cut down. 2001 ME 152, ¶¶ 1, 7, 782 A.2d at 765-66. The damages recovered pursuant to section 7552 were based on the replacement cost for the lost tree. Id. ¶ 13, 782 A.2d at 768. We vacated and amended the section 7552 award because the trial court measured the damages according to a willful standard rather than a negligent or without fault standard. Id. ¶¶ 13, 15-16, 782 A.2d at 768. Although we upheld the use of the replacement cost of the tree as an appropriate measure of section 7552 damages, the defendant had not challenged the measure of damages, and we analyzed the case pursuant to an old version of section 7552. 6 Id. ¶¶ 13, 16, 782 A.2d at 767-68. The language of section 7552 before its *852 revision did not enumerate the damages recoverable as it does in its current form; rather, it referred generally to “damages.” See 14 M.R.S.A. § 7552 (Supp.1994).

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Bluebook (online)
2006 ME 100, 903 A.2d 848, 2006 Me. LEXIS 117, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fuschetti-v-murray-me-2006.