Greenvall v. Maine Mut. Fire

CourtSuperior Court of Maine
DecidedJune 6, 2001
DocketKENcv-97-070
StatusUnpublished

This text of Greenvall v. Maine Mut. Fire (Greenvall v. Maine Mut. Fire) 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
Greenvall v. Maine Mut. Fire, (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION

KENNEBEC, ss. DOCKET NO. Cv- 97- 7-070). JEFFREY GREENVALL, Personal Representative of the Estate of Carla C. Madore,

Plaintiff

Vv. DECISION AND ORDER

MAINE MUTUAL FIRE INSURANCE COMPANY,

Defendant

This is a wrongful death action brought on a claim for underinsured motorist coverage. The jury returned a verdict form finding the other driver negligent and that the decedent suffered conscious pain and suffering as a consequence of the motor vehicle accident. By answers to its interrogatories on the verdict form, the jury awarded plaintiff $50,000 damages for conscious pain and suffering, $150,000 for loss of comfort, society, and companionship, and $50,000 pecuniary loss suffered by the heirs of the decedent. .

The decedent was killed on February 11, 1995. On that date, 18-A M.R.S.A. § 2- 804 , the Wrongful Death Statute, provided maximum recoverable damages for the loss of "comfort, society, and companionship" at $75,000. On July 7, 1995, the personal representative served a 14 M.R.S.A. § 1602 Notice of Claim on the defendant. On or about January 5, 1996, the personal representative settled the estate's tort claim against the other driver and issued a release therefor for payment of $100,000. On March 29, 1996, the Legislature amended the Wrongful Death Statute to increase the maximum

amount recoverable for the loss of comfort, society, and companionship to $150,000. This change was effective July 4, 1996. On April 4, 1997, nine months after the statutory change, the personal representative executed the complaint which was subsequently - served on the defendant and filed with the court.

The defendant argues that the increase of the statutory maximum from $75,000 to $150,000 subsequent to the death but prior to the initiation of the lawsuit does not affect the verdict in this case. Defendant argues that "It is well settled that the law in effect at the time of the execution of a contract becomes part of that contract." Portland Savings Bank v. Landry, 372 A.2d 573 (Me. 1977). “Substantive rights of the parties affixed the date upon which the cause of action accrued." Batchelder v. Tweedie, 294 A.2d 443 (Me. 1972).

Plaintiff argues that the increase in the statutory limitation is a procedural matter, effective on claims initiated subsequent to the statutory amendment regardless of the date of the death and that the increased statutory cap should apply in this case. Plaintiff cites Feighery v. York Hospital, 38 F.Supp. 3rd 142 (D.Me. 1999) and Roy v. Soucy, Somerset Cty. Super. Ct., Docket No. CV-96-148. Because Roy v. Soucy was decided by this court, noting that “neither party has cited any law in support of their position as to whether $150,000 or $75,000 is the maximum judgment that may be rendered in a wrongful death action in this case” , and because this matter has been fully briefed by the parties in the instant case, this court provides this written explanation of its judgment in this matter.

As with most American jurisdictions, in 1891 Maine joined Britain in enacting a Wrongful Death Statute. Under the common law, a person's death action dies with him. The Devona, 1 F.2d 482 (D.Me. 1924); Chase v. Inhabitants of Litchfield, 134 Me. 122,

182 A. 921 (1936). "The statute of 1891 ¢.124, giving the right of action from the death of

2 a person ‘caused by the wrongful act, neglect or default' of another is to be construed as a new statute creating a new right and not as affirming or reviving an ancient right.” _ McKay v. New England Dredging Co., 43 A 29,92 Me. 454 (1899).

Courts have long struggled with the problem of when a statute or amendment should be applied retrospectively. The source of this confusion has often been the use of the procedural/substantive dichotomy. The courts have “sometimes applied a presumption that procedural or remedial enactments are presumed to apply retroactively and that statutes affecting substantive rights are presumed to apply only prospectively.” Sinclair v. Sinclair, 654 A.2d 438, 439 (Me. 1995). Our Law Court, as well as many legal scholars and other state courts, has brought into doubt the usefulness of this analytical tool. Id. at 439-440. Referring to the “elusive distinction between substance and procedure,” the court observed that “[a]pplying a label foretells the result but does not materially contribute to a principled decision.” Id.1 This sentiment was earlier expressed in Langley v. Home Indemnity Company, 272 A.2d 740 (Me. 1971). The court took the position that labeling a statute as “remedial” provides little meaningful assistance. Id. at 745. “The classification of statutes as ‘remedial’ in a manner so comprehensive...erects a foundation far too extensive upon which to establish a principle which allows retrospective statutory scope and application.” Id. at 745-46, Both Sinclair and Langley instead relied on the “long and firmly established principle of statutory interpretation that: ‘A statute shall not have retrospective

operation unless its terms are so strong, clear, and imperative that no other meaning

2 The Law Court acknowledged that its own struggle with these concepts has “not always resulted in clearly defined pathways.” Sinclair, 654 A.2d at 439 (citing Riley v. Bath Iron Works Corp., 639 A.2d 626 (Me. 1994); Danforth v. L.L. Bean, Inc., 624 A.2d 1231 (Me. 1993); Schlear v. Fiber Materials, Inc., 574 A.2d 876 (Me. 1990), among others.

3 can be annexed to them, or unless the intention of the Legislature cannot be otherwise satisfied...” Id. at 746-747 (quoting In re Guilford Water Company, 118 Me. 367, 375, 108 © A, 446, 451 (1919)).

In a dissenting opinion with whom Justice Dana joined, Justice Lipez noted that the substantive/ procedural analysis should not be used in a contract case to determine whether a statute applies retroactively or prospectively. Sinclair, 654 A.2d at 441. Instead, three questions ought to be asked. First, whether the statute was enacted before or after the contract was executed. Second, if after, whether the Legislature intended that the statute apply retroactively. Third, if the Legislature so intended, whether the statute works an unconstitutional impairment of contract. Id. The dissenters noted that the procedural/substantive dichotomy was still useful if, and when the court reached the constitutional issue of impairment of contracts. Id. at n.1. The emphasis of the dissenting opinion, however, was on the fundamental rule of statutory construction that statutes are presumed to have a prospective application unless a legislative intent to the contrary “is clearly expressed or necessarily implied in the language used.” Id. (quoting Miller v. Fallon, 134 Me. 145, 148, 183 A. 416, 417 (1936)). The Legislature must express that intent in “strong, clear and imperative language.” Id. (quoting Terry v. St. Regis Paper, 459 A.2d 1106, 1109 (Me. 1983).

The Legislature amended 18-A M.R.5.A. § 2-804(b) on March 29, 1996 to increase

the amount recoverable for loss of comfort, society, and companionship of the

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Related

Landgraf v. USI Film Products
511 U.S. 244 (Supreme Court, 1994)
Terry v. St. Regis Paper Co.
459 A.2d 1106 (Supreme Judicial Court of Maine, 1983)
Portland Savings Bank v. Landry
372 A.2d 573 (Supreme Judicial Court of Maine, 1977)
Danforth v. L.L. Bean, Inc.
624 A.2d 1231 (Supreme Judicial Court of Maine, 1993)
Sinclair v. Sinclair
654 A.2d 438 (Supreme Judicial Court of Maine, 1995)
Riley v. Bath Iron Works Corp.
639 A.2d 626 (Supreme Judicial Court of Maine, 1994)
Schlear v. Fiber Materials, Inc.
574 A.2d 876 (Supreme Judicial Court of Maine, 1990)
Batchelder v. Tweedie
294 A.2d 443 (Supreme Judicial Court of Maine, 1972)
Dempsey v. State
451 A.2d 273 (Supreme Court of Rhode Island, 1982)
Langley v. Home Indemnity Company
272 A.2d 740 (Supreme Judicial Court of Maine, 1971)
McKay v. New England Dredging Co.
43 A. 29 (Supreme Judicial Court of Maine, 1899)
In re Guilford Water Co.
108 A. 446 (Supreme Judicial Court of Maine, 1919)
Chase v. Inhabitants of Litchfield
182 A. 921 (Supreme Judicial Court of Maine, 1936)
Miller v. Fallon
183 A. 416 (Supreme Judicial Court of Maine, 1936)
Joyce v. Convoy S. S. Co.
1 F.2d 482 (D. Maine, 1924)

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Greenvall v. Maine Mut. Fire, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greenvall-v-maine-mut-fire-mesuperct-2001.