Jared Goodell v. Brandie Wells Roof

CourtSupreme Court of New Hampshire
DecidedFebruary 12, 2025
Docket2023-0281
StatusUnpublished

This text of Jared Goodell v. Brandie Wells Roof (Jared Goodell v. Brandie Wells Roof) is published on Counsel Stack Legal Research, covering Supreme Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jared Goodell v. Brandie Wells Roof, (N.H. 2025).

Opinion

THE STATE OF NEW HAMPSHIRE

SUPREME COURT

In Case No. 2023-0281, Jared Goodell v. Brandie Wells Roof, the court on February 12, 2025, issued the following order:

The court has reviewed the written arguments and the record submitted on appeal, has considered the oral arguments of the parties, and has determined to resolve the case by way of this order. See Sup. Ct. R. 20(2). The counterclaim plaintiff, Brandie Wells Roof, appeals the entry of judgment, following a jury trial in Superior Court (Smith, J.), in favor of the counterclaim defendant, Jared Goodell. Roof also appeals a number of the trial court’s rulings in this case. She appeals orders by the Trial Court (Smith, J.): (1) denying her motion for attorney’s fees and costs; (2) ruling that her attorney’s fees could not be used as a measure of damages in her claim for fraudulent registration of trade names, see RSA 349:10 (2022); and (3) ruling that her suit could not include the private prosecution of a criminal violation of RSA 349:10. Roof also appeals orders by the Trial Court (Ruoff, J.) dismissing her claims: (1) under the Consumer Protection Act (CPA), see RSA 358-A:2 (2022) (amended 2024); (2) under 15 U.S.C. § 1125 for false designation; and (3) for conversion. Finally, she appeals an order of the Trial Court (Leonard, J.) granting Goodell’s motion for summary judgment on her economic duress claim. We uphold all of the enumerated rulings by the trial court, but reverse and remand for a new trial because the trial court erred in entering judgment based on the jury verdict.

The following facts are taken from the trial court’s orders. Goodell brought a defamation action against Roof, who responded with a number of counterclaims. Roof’s responsive pleading alleged that she operated a psychic medium business and a retail business in Keene under the common law trade names “Keene Intuition” and “Soul Emporium,” respectively. In August 2018, a local newspaper published an article that described Roof’s businesses and referenced both trade names. Immediately thereafter, Goodell registered both trade names with the Secretary of State. Goodell subsequently offered to release the trade names to Roof if she paid money and signed non- disclosure and non-disparagement agreements. She declined.

Roof’s counterclaims included a claim under RSA 349:10 for fraudulent registration of trade names and claims for both intentional and negligent infliction of emotional distress. By the time of trial, only those three counterclaims and claims for enhanced damages and attorney’s fees had survived motions for dismissal or summary judgment. Approximately two weeks prior to trial, Goodell voluntarily nonsuited his defamation claim with prejudice, leaving Roof’s remaining claims to be tried.

After a four-day trial, the jury was sent to deliberate with a verdict form that asked four questions, designated A, B, C, and D. The first three questions asked if the jury found that Roof had proved, respectively, each of her substantive counterclaims — fraudulent registration of a trade name (Question A), intentional infliction of emotional distress (Question B), and negligent infliction of emotional distress (Question C). The jury answered “no” to all three. Question D asked whether the jury found that Goodell’s conduct was wanton, malicious or oppressive and, if the answer was “yes,” instructed the jury to “enter the amount of enhanced compensatory damages, if any.” The jury answered “yes,” and entered the amount of $75,000.

Following a hearing, the trial court ruled that it could not issue an award of enhanced compensatory damages when the jury had found no liability on Roof’s substantive tort claims. The court entered judgment in favor of Goodell on the substantive claims and awarded no enhanced compensatory damages. Roof moved for reconsideration, judgment notwithstanding the verdict, and to set aside the verdict. Goodell objected, and the trial court denied the motions. Roof also requested an award of attorney’s fees on the basis of RSA 507:15 and Harkeem v. Adams, 117 N.H. 687 (1977), which the trial court denied. See RSA 507:15 (2010).

On appeal, Roof first argues that the trial court erred in setting aside the jury’s $75,000 verdict in her favor. She contends that the trial court’s conclusion that the enhanced damages award could not stand without a finding of liability on one of Roof’s underlying tort claims is unsupported by law. We disagree. In Vratsenes v. New Hampshire Auto, Inc., 112 N.H. 71 (1972), we noted:

In a civil action founded on a tort, nothing but compensatory damages can be awarded, but the injured party is entitled to full compensation for all the injury sustained, mental as well as material. In some cases, compensation for the actual material damage sustained will be full compensation. In other cases, the material damages may be trivial, and the principal injury be to the wounded feelings from the insult, degradation, and other aggravating circumstances attending the act.

Vratsenes, 112 N.H. at 73 (emphasis added) (quotation omitted); see also Minion Inc. v. Burdin, 929 F. Supp. 521, 523 (D.N.H. 1996) (noting that “[u]nder New Hampshire law, a claim for enhanced damages is not a separate cause of action; it is a request for a particular remedy”).

2 Question D on the verdict form asked:

Does the Jury find that Ms. Roof has proven by a preponderance of the evidence that [Goodell’s] conduct was wanton, malicious, or oppressive?

....

If your answer is YES, enter the amount of enhanced compensatory damages, if any.

By itself, Question D does not contain all the elements of any recognized tort. The trial court was therefore correct in concluding that the jury’s answers to Question D do not support an entry of judgment for $75,000. Cf. McVey v. Phillips Petroleum Company, 288 F.2d 53, 59 (5th Cir. 1961) (noting that the answers to interrogatories propounded to the jury could not support a judgment because, “although those interrogatories deal with compensation for injuries proximately resulting from the ‘accident made the basis of this suit,’ the element of negligence is nowhere mentioned”). Accordingly, the court did not err in declining to award the enhanced compensatory damages found by the jury.

Roof alternatively argues that the trial court should have granted a new trial based on inconsistency of the verdicts. The parties agree that a new trial is warranted if there is “no rational, non-speculative way to reconcile two essential jury findings.” Grant v. Westinghouse Elec. Corp., 877 F. Supp. 806, 810 (E.D.N.Y. 1995) (quotation omitted). Accordingly, we will assume, without deciding, that that standard applies. We review the denial of a motion to set aside the verdict and grant a new trial for an unsustainable exercise of discretion. See Brigham v. Hudson Motors, Inc., 118 N.H. 590, 593 (1978); State v. Lambert, 147 N.H. 295, 296 (2001).

Goodell contends that the verdicts can be rationally reconciled. He notes that the burden of proof stated in Question A was by clear and convincing evidence, while on Question D, the burden of proof was by a preponderance of the evidence. Thus, he argues, “[t]he jury could have found, by the preponderance of the evidence, that Goodell’s trade name registration was wanton, malicious or oppressive, but not fraudulent.” Even if we assume, however, that the jury could have so found, it still could not have answered Question D as it did consistently with the instructions it was given.

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Related

Grant v. Westinghouse Electric Corp.
877 F. Supp. 806 (E.D. New York, 1995)
Vratsenes v. N. H. Auto, Inc.
289 A.2d 66 (Supreme Court of New Hampshire, 1972)
Minion Inc. v. Burdin
929 F. Supp. 521 (D. New Hampshire, 1996)
Brigham v. Hudson Motors, Inc.
392 A.2d 130 (Supreme Court of New Hampshire, 1978)
Ralph P. Gallo & a. v. Susan Traina & a.
166 N.H. 737 (Supreme Court of New Hampshire, 2014)
Harkeem v. Adams
377 A.2d 617 (Supreme Court of New Hampshire, 1977)
State v. Lambert
787 A.2d 175 (Supreme Court of New Hampshire, 2001)
Great American Dining, Inc. v. Philadelphia Indemnity Insurance
62 A.3d 843 (Supreme Court of New Hampshire, 2013)

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Jared Goodell v. Brandie Wells Roof, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jared-goodell-v-brandie-wells-roof-nh-2025.