Jim Muncie v. Shield Enviromental Associates, Inc.

CourtCourt of Appeals of Kentucky
DecidedMarch 21, 2024
Docket2022 CA 001072
StatusUnknown

This text of Jim Muncie v. Shield Enviromental Associates, Inc. (Jim Muncie v. Shield Enviromental Associates, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jim Muncie v. Shield Enviromental Associates, Inc., (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 22, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1072-MR

JIM MUNCIE AND CINDY MUNCIE APPELLANTS

APPEAL FROM OLDHAM CIRCUIT COURT v. HONORABLE JERRY D. CROSBY, II, JUDGE ACTION NO. 13-CI-00688

SHIELD ENVIRONMENTAL ASSOCIATES, INC. AND PATRICIA WIESEMANN APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CALDWELL, AND CETRULO, JUDGES.

ACREE, JUDGE: Appellants, Jim and Cindy Muncie, appeal the Oldham Circuit

Court’s August 11, 2022 order dismissing their lawsuit for failure to prosecute

pursuant to CR1 41.02. The circuit court did so after four years of inaction

following remand of this case from the Kentucky Supreme Court. We conclude

1 Kentucky Rules of Civil Procedure. the circuit court did not abuse its discretion in dismissing the lawsuit and,

therefore, we affirm.

BACKGROUND

This case, which now makes its second appearance before this Court,

has a factual and procedural history which is greater than is necessary to resolve

the narrow issue presented in this appeal; namely, whether the circuit court erred

by dismissing Appellants’ lawsuit for failure to prosecute upon remand of their

case from the Kentucky Supreme Court. For the curious, a fuller account of the

underlying history of this dispute may be found in Muncie v. Wiesemann, 548

S.W.3d 877 (Ky. 2018). The background relevant to this appeal is as follows.

In 2010, 1,000 gallons of home heating oil leaked from an

underground tank on property owned by the Martha Magel estate. Muncie, 548

S.W.3d at 877-78. The oil flowed downhill and flooded Appellants’ residence,

causing massive damage. Id. at 878. Appellee Patricia Wiesemann managed the

Magel estate as testatrix. Id. Appellee Shield Environmental Associates, Inc.

(Shield Environmental) performed work on a sump pump at Appellants’ residence;

the sump pump subsequently malfunctioned. Brief for Appellee Shield

Environmental at 1.

Eventually, Appellants partially settled a resultant federal lawsuit and

$60,000 was allocated to Appellants to remedy actual damages to their property.

-2- Muncie, 548 S.W.3d at 878. However, the agreement reserved some of

Appellants’ claims, including “claims by [Appellants] asserting the diminution of

value of their real estate due to the stigma resulting from the contamination[.]” Id.

Appellants filed a state claim in the Oldham Circuit Court, and the

circuit court subsequently granted summary judgment in Appellees’ favor. Id.

The circuit court reasoned that “while stigma damages may be considered in the

measure of actual damages for remediation, [Appellants] could not seek both the

costs of remediation (i.e., the repair costs) and the diminution in value due to

stigma damages” and, therefore, Appellants had no further claim. Id. This Court

agreed, reasoning that “when there is actual damage to real property, stigma or

reputation damages may be included as a measure of damages . . . [however,] there

is not an independent right of recovery available for such damages.” Id. at 878-79

(modification original, internal quotation marks omitted).

The Supreme Court disagreed, holding that “if remediation damages

are settled but a claim on the stigma damages resulting from the actual injury is

reserved, then the injured party may be awarded stigma damages regardless of the

partial settlement on remediation.” Id. at 880. Accordingly, the Supreme Court

reversed and remanded for further proceedings to determine whether Appellants

had been compensated for diminution of value resulting from any stigma

-3- associated with the oil spill. Id. at 881. The Supreme Court entered its Order of

Remand on July 12, 2018.

Appellants took no action on their case upon its return to the circuit

court. Appellees each filed a motion to dismiss for lack of prosecution under CR

41.02(1) in June of 2022 – nearly four years after the Supreme Court remanded the

case. Appellants filed a response on July 15, stating personal difficulties

accounted for their inactivity in the lawsuit. More specifically, they stated that

Appellant Cindy Muncie’s mother was diagnosed with Alzheimer’s Disease, and

that Cindy alone supported her mother personally and financially. Cindy’s mother

died in 2019. Appellants’ attorney’s younger brother died suddenly later that year.

Cindy received a uterine cancer diagnosis in 2019. And Appellants noted the

economic and administrative challenges arising from the COVID-19 pandemic

made it difficult to pursue their lawsuit.

The circuit court granted the motions in an order entered August 11,

2022; though it sympathized with the losses of Appellants and their attorney, “the

effects of these events do not mean they were unable to do anything.” The court

concluded Appellants “failed to offer any substantial reason to justify such a long

delay in proceeding with this case.” Appellants appealed, bringing this Sisyphean

matter before this Court a second time.

-4- ANALYSIS

“For failure of the plaintiff to prosecute or comply with these rules or

any order of the court, a defendant may move for dismissal of an action or of any

claim against him.” CR 41.02(1). Unless the court specifies in its order, a

dismissal “other than a dismissal for lack of jurisdiction, for improper venue, for

want of prosecution under Rule 77.02(2), or for failure to join a party under Rule

19, operates as an adjudication upon the merits.” CR 41.02(3). A dismissal under

Rule 41.02 is distinct from a dismissal under Rule 77.02, a “housekeeping rule”

that requires courts to review their dockets annually and dismiss without prejudice

those cases wherein “no pretrial step has been taken within the last year[.]” CR

77.02(2); Wildcat Prop. Mgmt., LLC v. Reuss, 302 S.W.3d 89, 92 (Ky. App. 2009).

Conversely, a dismissal under Rule 41.02 is with prejudice. Wildcat Prop. Mgmt.,

302 S.W.3d at 92.

“Dismissals for lack of prosecution pursuant to CR 41.02 and CR

77.02 are reviewed under an abuse of discretion standard.” Toler v. Rapid

American, 190 S.W.3d 348, 351 (Ky. App. 2006) (citations omitted). A trial court

abuses its discretion when its decision is “arbitrary, unreasonable, unfair, or

unsupported by sound legal principles.” Sexton v. Sexton, 125 S.W.3d 258, 272

(Ky. 2004) (citations omitted). Additionally, “the involuntary dismissal of a case

with prejudice ‘should be resorted to only in the most extreme cases,’ and a

-5- reviewing court must ‘carefully scrutinize the trial court’s exercise in doing so.’”

Wildcat Prop. Mgmt., 302 S.W.3d at 93 (quoting Polk v. Wimsatt, 689 S.W.2d 363,

364-65 (Ky. App. 1985)).

As the circuit court did in its order, trial courts may consider the six

factors supplied by Ward v. Housman to determine whether dismissal with

prejudice pursuant to CR 41.02 is appropriate. 809 S.W.2d 717, 719 (Ky. App.

1991) (citations omitted). These factors are “1) the extent of the party’s personal

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Related

Sexton v. Sexton
125 S.W.3d 258 (Kentucky Supreme Court, 2004)
Toler v. Rapid American
190 S.W.3d 348 (Court of Appeals of Kentucky, 2006)
Polk v. Wimsatt
689 S.W.2d 363 (Court of Appeals of Kentucky, 1985)
WILDCAT PROPERTY MANAGEMENT, LLC v. Reuss
302 S.W.3d 89 (Court of Appeals of Kentucky, 2009)
Jaroszewski v. Flege
297 S.W.3d 24 (Kentucky Supreme Court, 2009)
Ward v. Housman
809 S.W.2d 717 (Court of Appeals of Kentucky, 1991)
Muncie v. Wiesemann
548 S.W.3d 877 (Missouri Court of Appeals, 2018)

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Jim Muncie v. Shield Enviromental Associates, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jim-muncie-v-shield-enviromental-associates-inc-kyctapp-2024.