Pulte Homes v. Adele Simerly

CourtCourt of Appeals of Georgia
DecidedJuly 8, 2013
DocketA13A0065
StatusPublished

This text of Pulte Homes v. Adele Simerly (Pulte Homes v. Adele Simerly) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pulte Homes v. Adele Simerly, (Ga. Ct. App. 2013).

Opinion

SECOND DIVISION BARNES, P. J., MILLER and RAY, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

July 8, 2013

In the Court of Appeals of Georgia A13A0065. PULTE HOME v. SIMERLY et al.

MILLER, Judge.

Tim and Adele Simerly and Richard and Susan Trent sued Pulte Home

Corporation (“Pulte”), raising claims of trespass, nuisance, negligence, negligence per

se, riparian rights, unjust enrichment, and ejectment based on the company’s actions

in causing excess storm water and sediment to enter the Simerlys’ and Trents’

properties. Pulte filed third-party complaints against Sally and Dwayne Lawson and

Ruth Benefield (collectively, the “Lawsons”), alleging that a bridge on the Lawsons’

property was the cause of damage to the properties owned by the Simerlys and Trents.

The Lawsons filed counter-claims against Pulte that were similar to the claims

asserted by the Simerlys and Trents. The suits were consolidated and proceeded to a

jury trial, where the jury found in favor of the Simerlys, Trents, and Lawsons (collectively, the “Plaintiffs) and awarded them $2.49 million in damages and

attorney fees. Pulte filed a motion for new trial following the entry of judgment,

which the trial court denied. Pulte appeals, contending that the trial court erred in (1)

denying Pulte’s motion in limine to preclude Plaintiffs’ counsel from testifying at

trial; (2) failing to enforce the Georgia Rules of Professional Conduct requiring

counsel to elicit only truthful evidence and failing to give a requested curative

instruction following the presentation of false testimony; and (3) denying Pulte’s

motion in limine to preclude Plaintiffs from referencing Pulte’s violations of the

Clean Water Act (“CWA”) and state statutes implementing the CWA. For the reasons

that follow, we affirm.

Construed in favor of the verdict,1 the evidence shows that in January 2004,

Pulte purchased property in Forsyth County to develop single-family residences for

what would become the Notting Hill and Fieldstone subdivisions (“Pulte

Development”). The Pulte Development discharged water into Harris Creek and was

located upstream of the Plaintiffs’ properties. Pulte had purchased the property from

Macauley Properties, which previously hired Lowe Engineering to complete a

1 Turner Broadcasting System, Inc. v. McDavid, 303 Ga. App. 593, 593-594 (693 SE2d 873) (2010).

2 hydrology and storm water management study (“Lowe Study”). The Lowe Study was

completed in January 2004, and Pulte relied upon the study to design and construct

the Pulte Development. The Lowe Study recommended that storm water discharges

from future developments could be controlled with the construction of a weir on

Harris Creek, which consisted of a partial wall across the creek, above Drew

Campground Road located within Fieldstone. The weir on Harris was constructed by

Macauley Properties.

Pulte began mass grading and other land disturbing activities at Fieldstone in

March 2004. Shortly thereafter, excessive amounts of storm water, dirt, sediment, and

development debris were discharged into Harris Creek and ultimately into the ponds

located on the Plaintiffs’ properties. Investigations revealed that the discharged

sediment and pollutants were caused by Pulte’s activities upstream and its failure to

install and maintain erosion control devices required by law. The Pulte Development

also caused a dramatic increase in the rate and flow of storm water discharge into

Harris Creek that caused flooding to the Plaintiffs’ properties. During a subsequent

study, it was discovered that the weir was inadequate to control the storm water

discharge from the Pulte Development because the Lowe Study, upon which Pulte

3 had relied for storm water management, was based upon flawed assumptions and

analysis.

1. Pulte contends that the trial court erred in denying its motion in limine to

preclude the Simerlys’ counsel from testifying at trial as to what occurred during a

May 2009 document review. We disagree.

“In reviewing the denial of a motion in limine, this Court must construe the

evidence most favorably to the upholding of the trial court’s findings and judgment,

and we cannot reverse a trial court’s ruling absent an abuse of discretion.” (Citations

omitted.) Hood v. State, 291 Ga. App. 881, 882 (663 SE2d 297) (2008). “A motion

in limine is properly granted when there is no circumstance under which the evidence

under scrutiny is likely to be admissible at trial.” (Punctuation and footnote omitted.)

Hankla v. Jackson, 305 Ga. App. 391, 392 (1) (699 SE2d 610) (2010).

During litigation, the trial court found that Pulte had engaged in spoilation by

deleting emails relevant to the litigation, and enjoined Pulte from engaging in further

destruction of evidence. The trial court had appointed a Special Discovery Master to

oversee compliance with the court’s injunction and to resolve other discovery issues,

including the attempted recovery of spoilated evidence through a computer forensic

investigation. The Special Discovery Master issued a report outlining that the

4 computer forensic investigation revealed that Pulte had engaged in further spoilation

of electronic evidence after the trial court’s order and recommended that Pulte be

sanctioned for its violations. The trial court adopted the Special Discovery Master’s

report and recommendation.

The Special Discovery Master also informed the trial court that the Simerlys’

counsel and Pulte’s counsel had provided conflicting statements relating to Pulte’s

removal of discovery documents during a May 2009 document review at Pulte’s

offices. At a subsequent hearing before the trial court, Simerlys’ counsel, Michael

Carvalho, testified that he and an associate attorney, Christine Westberg, had a

scheduled document review at Pulte’s offices in May 2009. Carvalho testified that

during the document review, he had stacked a number of documents in a pile that

were deemed relevant in order to copy them. Before taking a break for lunch,

Carvalho informed Pulte’s counsel that they planned to copy the documents in the

stack. When Carvalho returned from lunch, he noticed that the stack of documents

was smaller. Carvalho testified that he asked Pulte’s counsel about the missing

documents, and she told him that she took the documents because they were

privileged. Following the hearing, the trial court found that Pulte’s counsel had taken

documents during the document review.

5 About two weeks prior to trial, Pulte filed the instant motion in limine seeking

to preclude the Plaintiffs from mentioning what transpired during the May 2009

document review. Pulte argued that any evidence with respect to the May 2009

document review would rely either on Carvalho’s testimony, which was improper

under Rule 3.7 (a) of the Rules of Professional Conduct, or the trial court’s order,

which would amount to an impermissible comment on the evidence. The trial court

denied Pulte’s motion in limine and allowed Carvalho to testify about spoilation

during the May 2009 document review, finding that forcing him to withdraw at the

late stage of the proceedings would cause a substantial hardship to the Simerlys and

would allow Pulte to benefit from its discovery violations.

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

Related

Hood v. State
663 S.E.2d 297 (Court of Appeals of Georgia, 2008)
Bell v. Bell
79 S.E.2d 524 (Supreme Court of Georgia, 1954)
Hamilton v. Shumpert
682 S.E.2d 159 (Court of Appeals of Georgia, 2009)
Citadel Corp. v. All-South Subcontractors, Inc.
458 S.E.2d 711 (Court of Appeals of Georgia, 1995)
Rockefeller v. Kaiser Foundation Health Plan
554 S.E.2d 623 (Court of Appeals of Georgia, 2001)
Coastal Marshlands Protection Committee v. Center for a Sustainable Coast
649 S.E.2d 619 (Court of Appeals of Georgia, 2007)
McLain v. Mariner Health Care, Inc.
631 S.E.2d 435 (Court of Appeals of Georgia, 2006)
Dupree v. Keller Industries, Inc.
404 S.E.2d 291 (Court of Appeals of Georgia, 1991)
Turner Broadcasting System, Inc. v. McDavid
693 S.E.2d 873 (Court of Appeals of Georgia, 2010)
Hubbard v. Department of Transportation
568 S.E.2d 559 (Court of Appeals of Georgia, 2002)
Hankla v. Jackson
699 S.E.2d 610 (Court of Appeals of Georgia, 2010)
Schaff v. State
697 S.E.2d 305 (Court of Appeals of Georgia, 2010)
Jenkins v. Wachovia Bank, N.A.
724 S.E.2d 1 (Court of Appeals of Georgia, 2012)
Francois v. State
711 S.E.2d 45 (Court of Appeals of Georgia, 2011)
Stolte v. Fagan
731 S.E.2d 653 (Supreme Court of Georgia, 2012)
Phelps v. Huff
448 S.E.2d 64 (Court of Appeals of Georgia, 1994)
Upper Chattahoochee Riverkeeper, Inc. v. Forsyth County
734 S.E.2d 242 (Court of Appeals of Georgia, 2012)
Kroger Co. v. Walters
735 S.E.2d 99 (Court of Appeals of Georgia, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Pulte Homes v. Adele Simerly, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pulte-homes-v-adele-simerly-gactapp-2013.