McNeil v. Hogan

CourtSuperior Court of Maine
DecidedJanuary 5, 2009
DocketCUMcv-07-121
StatusUnpublished

This text of McNeil v. Hogan (McNeil v. Hogan) 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
McNeil v. Hogan, (Me. Super. Ct. 2009).

Opinion

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ANN MARIE MCNEIL, et al.,

Plaintiffs,

v. ORDER

BRIAN HOGAN, et al.,

Defendants.

Before the court are three motions for summary judgment. The first is a motion

by defendant Hudson-RPM Distributors LTD for summary judgment contending that

the undisputed facts establish that Hudson-RPM cannot be vicariously liable for the

alleged wrongdoing of its employee, defendant Brian Hogan. This motion is opposed

by both Hudson-RPM's co-defendant, Brian Hogan, and by plaintiffs Ann Marie and

Donald McNeil.

The second and third motions for summary judgment are motions brought by

both Hudson-RPM and Hogan contending that the evidence offered by plaintiffs as to

the alleged causation of Ann Marie McNeil's injuries is insufficient and does not raise a

disputed issue for trial.

1. Summary Judgment

Summary judgment should be granted if there is no genuine dispute as to any

material fact and the movant is entitled to judgment as a matter of law. In considering a

motion for summary judgment, the court is required to consider only the portions of the

record referred to and the material facts set forth in the parties' Rule 56(h) statements.

E.g., Johnson v. McNeil, 2002 ME 99

summary judgment, any factual disputes must be resolved against the movant.

Nevertheless, when the facts offered by a party in opposition to summary judgment

would not, if offered at trial, be sufficient to withstand a motion for judgment as a

matter of law, summary judgment should be granted. Rodrigue v. Rodrigue, 1997 ME 99

2. Vicarious Liability

Hudson-RPM's stand-alone motion for summary judgment, filed May 28,2008, is

based on the contention that Maine has not yet recognized the tort of negligent

supervision and that the undisputed facts preclude a finding that Hogan was acting in

the course and scope of his employment if he committed an intentional tort against Mrs.

McNeil. In response, plaintiffs have forsworn any claim of negligent supervision

against Hudson-RPM and have also forsworn any claim that Hogan committed an

intentional tort. See Plaintiffs' Opposition to Defendants' Three Motions for Summary

Judgment dated June 20,2008 at 4.

The court has reviewed the complaint and concludes that while it can be

construed as alleging an intentional tort against Hogan, it can also be construed as

asserting a negligence claim against Hogan and a simple vicarious liability claim

against Hudson-RPM. See Complaint

the court establishes a disputed issue for trial as to whether Hogan's conduct was

within the scope of his employment, thereby potentially subjecting Hudson-RPM to

vicarious liability. See Mahar v. Stonewood Transport, 2003 ME 63

544, quoting Restatement (Second) Agency § 228.

2 3. Causation

The remaining summary judgment motions, filed by both Hudson-RPM and

Hogan on May 30, 2008, were originally premised on the ground that plaintiffs had not

submitted any admissible evidence of causation and were accompanied by motions in

limine seeking to exclude the expert causation testimony to be offered by plaintiffs, based on defendants' depositions of the physicians who had been designated as experts

on plaintiffs' behalf. In their expert designations plaintiffs had designated six medical

professionals and defendants filed motions in limine relating to all six.

In response defendants withdrew the designations of three medical professionals

and submitted affidavits from Drs. Vincent Herzog, Peter Ocampo, and Stephen

Rodrigue which plaintiffs contend remedy any defects in their deposition testimony.]

In brief summary, at Dr. Herzog's deposition he testified that he would like to

look at plaintiff's complete file before offering an opinion on causation, that he only had

10 percent of the relevant medical records and was not prepared to give an opinion as

to permanency, and that he was not offering any opinion as to the cause of Mrs.

McNeil's foot symptoms or her RSD. Herzog Dep. 10, 23,64. 2 The gist of Dr. Ocampo's

testimony was that plaintiff's foot condition appeared to be caused by the incident

involving defendant Hogan even thought he was reluctant to offer an opinion on

causation based on the information he was aware of at that time. Ocampo Dep. 55-56.

Dr. Rodrigue expressed the opinion that plaintiff's shoulder injury was "aggravated" by

] Hudson-RPM suggests that the affidavits should be disregarded because it contends that the affidavits contradict the doctors' deposition testimony. See Schnidler v. Nilsen, 2001 ME 58 «j[ 9, 770 A.2d 638, 641-42. The affidavits, however, are not so dearly contradictory that they may be disregarded. See Marcoux v. Parker HannifinlNichols Portland Division, 2005 ME 107

3 the motor vehicle accident but he would have wanted additional information before

concluding that the motor vehicle accident was the sole cause of Mrs. McNeil's arthritis.

Rodrigue Dep. 11-12.

Absent any of the subsequently submitted affidavits, the court would conclude

that the deposition testimony of Drs. Rodrigue and Ocampo would be sufficient to

survive summary judgment on the issue of causation. 3 Dr. Rodrigue's opinions relate to

Mrs. McNeil's shoulder injury. Dr. Ocampo's opinions relate to her foot injury and his

opinion that her foot injury had developed into a chronic pain condition.

As far as the court can tell, only Dr. Herzog at his deposition declined to offer

opinions as to causation or permanency, although he has now done so on his

subsequently submitted affidavit. Dr. Herzog's opinions overlap with those of Drs.

Rodrigue and Ocampo in that he offers opinions as to Mrs. McNeil's shoulder injury,

her foot injury, and also her back and neck injuries. 4 Of all these injuries, only Mrs.

McNeil's foot injury and the chronic pain condition allegedly resulting from her foot

injury appear to pose causation issues of special complexity.

4. Discovery Violations

Although plaintiffs' case has survived summary judgment, the procedure

followed in this case by counsel for plaintiffs is unacceptable. In each case, the doctors

in question were designated to give certain opinions as to causation and permanency

3 This is true because Dr. Rodrigue testified that the motor vehicle accident had at least aggravated Mrs. McNeil's shoulder condition, and any deficiencies as to Dr. Ocampo's testimony went primarily to weight.

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Related

Johnson v. McNeil
2002 ME 99 (Supreme Judicial Court of Maine, 2002)
Rodrigue v. Rodrigue
1997 ME 99 (Supreme Judicial Court of Maine, 1997)
Marcoux v. Parker Hannifin/Nichols Portland Division
2005 ME 107 (Supreme Judicial Court of Maine, 2005)
Schindler v. Nilsen
2001 ME 58 (Supreme Judicial Court of Maine, 2001)
Mahar v. StoneWood Transport
2003 ME 63 (Supreme Judicial Court of Maine, 2003)

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McNeil v. Hogan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcneil-v-hogan-mesuperct-2009.