Kandel v. Smoker

783 F. Supp. 948, 1991 U.S. Dist. LEXIS 19521, 1991 WL 316927
CourtDistrict Court, D. Maryland
DecidedDecember 11, 1991
DocketCiv. No. L-90-1809
StatusPublished

This text of 783 F. Supp. 948 (Kandel v. Smoker) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kandel v. Smoker, 783 F. Supp. 948, 1991 U.S. Dist. LEXIS 19521, 1991 WL 316927 (D. Md. 1991).

Opinion

MEMORANDUM AND ORDER

LEGG, District Judge.

The Court has been called upon to decide whether plaintiffs should be granted leave to amend their complaint to add a claim for punitive damages. Defendant’s opposition argues that the proposed Amended Complaint (Second Revised) should be denied because it fails to state a claim for punitive damages under Maryland law and would be futile as amended. For the reasons stated herein, plaintiffs’ Motion for Leave to File Amended Complaint is hereby denied.

I. FACTS

On July 3, 1991, plaintiffs filed the underlying complaint against defendant Wayne Clayton Smoker (“Smoker”). Plaintiff Nelson R. Kandel is the personal representative of the Estate of decedent Don Farley Reaves; plaintiff Lettie Reaves is decedent’s widow. On March 6, 1990, the decedent died when his pick-up truck collided with a tractor-trailer truck driven by Smoker. Plaintiffs’ complaint alleges that Smoker negligently caused the accident by pulling out of a parking lot onto U.S. Route 40, thereby blocking decedent’s oncoming vehicle. The complaint states two causes of action: Count I is a survival action and Count II is an action for wrongful death.

Plaintiffs’ original complaint requested actual and compensatory damages, but did not claim punitive damages. On October 24, 1991, plaintiffs filed a motion to amend their survival action under Count I by adding a claim for exemplary damages. The proposed Amended Complaint (Second Revised) alleges in pertinent part that:

Defendant was parked on a private parking lot more than twenty feet (20') from the roadbed. From this position [949]*949Defendant began moving and, without stopping and checking traffic, continued onto the roadway, blocking all lanes of traffic and escape for the decedent, Don Farley Reaves.
Defendant’s vehicle was capable of turning directly onto the right shoulder or right lane of the roadway. Further, Defendant’s vehicle was of such an unusual configuration so as to give rise to a higher decree [sic] of care than a standard tractor-trailer type combination.
Defendant’s actions were less than what an inattentive driver would have taken in protecting safety and property.
That the Defendant’s action in causing Don Farley Reaves’ death through his negligence were of such an extraordinary and outrageous nature as to constitute wilful and wanton disregard for human life.

Defendant opposed this motion and the matter was fully briefed.1 The Court has reviewed the parties’ papers and has concluded that no hearing on plaintiffs’ motion is necessary. Local Rule 105.6.

II. DISCUSSION

A. Standard of Review

Because defendant answered the original complaint on November 1, 1990, the plaintiffs may amend their complaint only through leave of this Court. See Fed. R.Civ.P. 15(a). As provided under Rule 15(a), leave to amend “shall be freely given when justice so requires.” Nevertheless, the grant or denial of leave to amend is a matter that is within the discretion of the trial court. See Justice v. Pennzoil Co., 598 F.2d 1339 (4th Cir.), cert. denied, 444 U.S. 967, 100 S.Ct. 457, 62 L.Ed.2d 380 (1979).

The purpose of Rule 15(a) is to “provide maximum opportunity for each claim to be decided on its merits rather than on procedural technicalities.” 6 Wright, Miller & Kane, Federal Practice & Procedure § 1471 (1990); see also Island Creek Coal Co. v. Lake Shore, Inc., 832 F.2d 274 (4th Cir.1987). If, however, “the proposed change clearly is frivolous or advances a claim or defense that is legally insufficient on its face, the court may deny leave to amend.” Id. at § 1487; see also Joyner v. Abbott Laboratories, 674 F.Supp. 185 (E.D.N.C.1987). Because plaintiffs’ claim of punitive damages is insufficient under Maryland law, leave to amend will be denied.

B. Analysis

Because the jurisdiction of this Court is founded upon diversity of citizenship and the accident occurred in Maryland, the law of this state applies. See Erie Railroad v. Tompkins, 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188 (1938). The controlling Maryland case as to punitive damages in an automobile personal injury matter is Smith v. Gray Concrete Pipe Co., Inc., 267 Md. 149, 297 A.2d 721 (1972).

In answering a question certified to it by the United States District Court for the Eastern District of Virginia, the Maryland Court of Appeals enunciated the standard by which the sufficiency of claims for exemplary damages arising out of automobile accidents are to be tested. Smith, 297 A.2d at 731, 732. The Court of Appeals held that the standard is as follows:

We regard a “wanton or reckless disregard for human life” in the operation of a motor vehicle, with the known dangers and risks attendant to such conduct, as the legal equivalent of malice. It is a standard which, although stopping just short of wilful or intentional injury, contemplates conduct which is of an extraordinary or outrageous character. Yet, it is both a functional and definitive test which, as we have noted, enjoys the virtue of having been frequently applied in this case. And if, as a test, it has been regarded as adequately stringent to [950]*950serve as a basis for possible imprisonment [for the crime of manslaughter by motor vehicle], then, surely, there appears to be no valid reason for deeming it too liberal for imposing civil sanctions. We hold that it is the standard by which claims for exemplary damages arising out of motor vehicle operation are to be tested.

Smith, 297 A.2d at 731.

While the Smith Court acknowledged the availability of punitive damages in automobile tort cases, it cautioned that a complaint seeking exemplary damages must set forth facts which demonstrate the defendant’s wanton or reckless disregard for human life. Finding that bald or con-clusory allegations of recklessness were insufficient to state a claim for punitive damages, the Court of Appeals stated:

[s]ince we recognize that the adoption of such a rule frequently tends to appear invitational, a caveat is in order concerning the pleading and proof requirements which we shall impose in future cases. As we shall note later, the allegations relied upon here by plaintiffs are set forth in considerable detail in the complaint. ' Such particularity may well serve as á benchmark for pleading a case of exemplary damages, at least in motor vehicle cases. No bald or conclusory allegations of “wanton or reckless disregard for human life,” or language of similar import, shall withstand attack on grounds of insufficiency.

Smith, 297 A.2d at 732.

The facts of Smith,

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Related

Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
Joyner v. Abbott Laboratories
674 F. Supp. 185 (E.D. North Carolina, 1987)
Baublitz v. Henz
535 A.2d 497 (Court of Special Appeals of Maryland, 1988)
Smith v. Gray Concrete Pipe Co.
297 A.2d 721 (Court of Appeals of Maryland, 1973)
Nast v. Lockett
539 A.2d 1113 (Court of Appeals of Maryland, 1988)
Justice v. Pennzoil Co.
598 F.2d 1339 (Fourth Circuit, 1979)

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Bluebook (online)
783 F. Supp. 948, 1991 U.S. Dist. LEXIS 19521, 1991 WL 316927, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kandel-v-smoker-mdd-1991.