Kueter v. Chrysler Fin. Corp.

CourtSuperior Court of Maine
DecidedAugust 22, 2000
DocketKENcv-98-202
StatusUnpublished

This text of Kueter v. Chrysler Fin. Corp. (Kueter v. Chrysler Fin. Corp.) 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
Kueter v. Chrysler Fin. Corp., (Me. Super. Ct. 2000).

Opinion

STATE OF MAINE SUPERIOR COURT CIVIL ACTION KENNEBEC, ss. DOCKET NO. CV-98-202

DRM- KEU- 2[aalaooe CYNTHIA M. KUETER,

Plaintiff Vv. ORDER ON DEFENDANTS’ - MOTIONS FOR CHRYSLER FINANCIAL CORPORATION SUMMARY JUDGMENT

and AMERICAN AUTO TRANSPORT & RECOVERY,

Defendants

This matter is before the court on defendant Chrysler Financial Corporation’s motion for summary judgment on all remaining claims in the complaint and defendant American Auto Transport & Recovery’s motion for summary judgment on all remaining claims in the complaint.

On December 12, 1996, plaintiff Cynthia Kueter bought a 1995 pickup truck from, and secured financing for it through, Morong Brunswick. Morong Brunswick assigned this loan to defendant Chrysler Financial Corporation (“Chrysler”). Kueter stopped making the payments for her truck and efforts were then begun by Chrysler and defendant American Auto Transport & Recovery (“American Auto”) to force Kueter to turn over the truck for repossession or to resume making payments. This lawsuit arises out of the defendants’ efforts to resolve this matter. On August 5, 1998, Kueter filed, pro se, a 38-page complaint against Chrysler. Chrysler removed

this action to the United States District Court for the District of Maine. On motion

for a more definite statement, Kueter filed a 39-page amended complaint.

Thereafter, Kueter retained counsel and on an unopposed motion to amend the amended complaint, Kueter filed a second amended complaint. This complaint adds American Auto as a defendant and asserts five counts brought under the common law and state and federal statutes. Ultimately, the United States District Court granted defendants’ summary judgment on all of Kueter’s claims brought under the Maine and Federal Fair Debt Collection Acts on the grounds that those claims were barred by the statute of limitations. The United States District Court then remanded the remaining state claims to this court. In considering these remaining claims, the United States District Court noted:

Although Kueter only requests relief under the MFDCPA and the

FFDCPA, she has alleged that Defendants violated the Maine

Consumer Credit Code and the common law. Based on her Amended

Complaint, it is unclear what common law violations, other than

trespass, she is asserting. Following remand, both defendants filed separate motions for summary judgment on the remaining claims in the complaint.

Before this court can consider the merits of the summary judgment motions, it must first decide what are the remaining claims in the complaint. There is a dispute between the parties as to whether count I properly asserts a claim under the Maine Consumer Credit Code, 9-A M.R.S.A. § 5-116(A), (B), because, although it alleges a violation of that code, it does not request judgment pursuant to that statute. Second, there is a dispute as to what common law claims are alleged.

Although the parties agree that count ITI alleges a claim for trespass, Kueter asserts

that her complaint also alleges claims for intentional infliction of emotional distress “e

and negligent infliction of emotional distress in count I and negligent and intentional misrepresentation in count II.

Regarding the claim under the Maine Consumer Credit Code, M.R. Civ. P. 54(c) states that “every judgment shall grant the relief to which the party in whose favor it is rendered is entitled even if the party has not demanded such relief in his pleadings.” Thus, under the plain language of the rules, Kueter was not required to request relief under the Consumer Credit Code in order to be awarded such relief.!

Chrysler relies on Rodriguez v. Doral Mfg. Co., 57 F.3d 1168 (1st Cir. 1995) in arguing that absent a request for judgment, this claim was not properly pled and, therefore, must be dismissed. In that case, the First Circuit found that Rule 54(c) of the Federal Rules of Civil Procedure “creates no right to relief premised on issues not presented to, and litigated before, the trier.” (Quoting Dopp v. HTP Corp., 947 F.2d 506, 618 (1st Cir. 1991)). “Thus, Rule 54(c)’s concern for appropriate relief does not include relief which a plaintiff has foregone because of failures in the pleadings or in the proof.” However, that is not the situation presented in the instant case.

Kueter has properly alleged a violation of the Maine Consumer Credit Code. She

1 See also 2 Field, McKusick & Wroth, Maine Civil Practice, § 54.4 at 10 nd ed. 1970) (“A plaintiff should receive the judgment to which he is entitled where the defendant has actually appeared and litigated, or had the opportunity to litigate, the issue, without being limited to his ad damnum or other demand for judgment.”).

2 In Rodriguez,

[t]he plaintiff wholly failed to plead a Law 17 claim. Her complaint did not delineate such a claim when filed; she did not add one by formal amendment; she did not mention the statute in her pretrial filings; and she did not explicitly refer to it at any point during the trial. In short, this is not a case in which a properly pleaded legal theory has been obscured by the parties’ concentration on other theories, ... but, rather, a case in which a particular legal theory was never so much as a gleam in the pleader’s eye.

3 was not required to allege anything more in order to obtain relief under that code. Thus, this claim is properly before this court.

Whether Kueter has properly alleged claims of intentional infliction of emotional distress, negligent infliction of emotional distress, and negligent and intentional misrepresentation, is less clear. “Modern notice pleading practice requires ‘a short and plain statement of the claim’ to provide fair notice of the cause of action, M.R. Civ. P. 8(a), but use of any particular ‘magic’ words are not required to state a particular claim.” Town of Stonington v. Galilean Gospel Temple, 1999 ME 2,{ 13, 722 A.2d 1269. The court is required to construe the “pleadings in favor of the pleader and in the interests of substantial justice.” (Quoting Chiappetta v. LeBlond, 505 A.2d 783 (Me. 1986)). “The function of the complaint is to provide fair notice of a claim.’ . . . It must sufficiently apprise defendants of the nature of the action against them” Bolton v. Caine, 584 A.2d 615 (Me. 1990) (quoting Rubin v. Josephson, 478 A.2d 665, 669 n.4 (Me. 1984)). “This notice-giving function of pleading is ‘sufficiently performed by a rather generalized statement.’”” Richards v. Soucy, 610 A.2d 268 (Me. 1992) (quoting 1 Field, McKusick & Wroth, Maine Civil Practice § 8.2 at 192-93 (2nd ed. 1970)).

Kueter asserts that count I alleges claim of intentional infliction of emotional distress and negligent infliction of emotional distress. Count I is entitled “Harassment and Abuse” and alleges that “Tdjefendants’ actions in their attempts to

collect a debt and repossess Plaintiff's vehicle constitute harassment and abuse

under the common law and the Maine Fair Debt Collection Practices Act, ... and the

Maine Consumer Credit Code,....” None of the factual allegations incorporated

into count I mention or allege that Kueter has suffered from emotional distress as a

result of defendants’ actions.”

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rodriguez-Bruno v. Doral Mortgage
57 F.3d 1168 (First Circuit, 1995)
Town of Stonington v. Galilean Gospel Temple
1999 ME 2 (Supreme Judicial Court of Maine, 1999)
Cloutier, Barrett, Cloutier & Conley, P.A. v. Wax
604 A.2d 42 (Supreme Judicial Court of Maine, 1992)
Prescott v. State Tax Assessor
1998 ME 250 (Supreme Judicial Court of Maine, 1998)
Bolton v. Caine
584 A.2d 615 (Supreme Judicial Court of Maine, 1990)
Richards v. Soucy
610 A.2d 268 (Supreme Judicial Court of Maine, 1992)
Searles v. Trustees of St. Joseph's College
695 A.2d 1206 (Supreme Judicial Court of Maine, 1997)
Fleet Bank of Maine v. Griffin
1997 ME 45 (Supreme Judicial Court of Maine, 1997)
Handy Boat Service, Inc. v. Professional Services, Inc.
1998 ME 134 (Supreme Judicial Court of Maine, 1998)
Corey v. Norman, Hanson & DeTroy
1999 ME 196 (Supreme Judicial Court of Maine, 1999)
Rubin v. Josephson
478 A.2d 665 (Supreme Judicial Court of Maine, 1984)
Chiappetta v. LeBlond
505 A.2d 783 (Supreme Judicial Court of Maine, 1986)
Capodilupo v. Town of Bristol
1999 ME 96 (Supreme Judicial Court of Maine, 1999)
Mariello v. Giguere
667 A.2d 588 (Supreme Judicial Court of Maine, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Kueter v. Chrysler Fin. Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kueter-v-chrysler-fin-corp-mesuperct-2000.