Remy v. Ford Motor Co.

48 V.I. 141, 2006 WL 3937343, 2006 V.I. LEXIS 28
CourtSuperior Court of The Virgin Islands
DecidedNovember 30, 2006
DocketCase No. SX-95-CV-357
StatusPublished
Cited by1 cases

This text of 48 V.I. 141 (Remy v. Ford Motor Co.) is published on Counsel Stack Legal Research, covering Superior Court of The Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Remy v. Ford Motor Co., 48 V.I. 141, 2006 WL 3937343, 2006 V.I. LEXIS 28 (visuper 2006).

Opinion

DONOHUE, Judge

MEMORANDUM OPINION

(November 30, 2006)

This matter is before the Court on Third-Party Defendant Ford Motor Company’s Motion to Dismiss for Spoliation of Evidence or, in the alternative for Lack of Prosecution. For the following reasons, Defendant’s motion is GRANTED on both grounds.

[144]*144I. BACKGROUND

In this action for damages, original Plaintiffs Clarence and Carrol Nathaniel (“Nathaniels”) allege that on March 29, 1994, they were passengers in a 1993 Ford Ranger pickup truck (“truck” or “vehicle”) with Louis Remy (“Remy”) when Remy lost control of his vehicle, ran off the shoulder of the road and impacted a tree. The Nathaniels allege that they suffered injuries as a result. According to Louis Remy’s interrogatory responses, he claims that prior to the accident, the truck’s steering wheel was not operating correctly, and that he made several unsuccessful attempts to have the vehicle serviced by the local Ford dealer. After the accident, Remy had the vehicle successfully inspected by Mr. Roy Gumbs, his own mechanic. Mr. Gumbs allegedly found defects in the truck, defects that Remy asserts are attributable to Ford Motor Company (“Ford”), the manufacturer of the truck. However, after Remy’s mechanic inspected the truck, the truck disappeared. Remy claims that he turned the truck over to his insurance company and since then he has been unable to recover or inspect the vehicle. Yet Ford never had an opportunity to inspect the truck, nor does the vehicle have any independent inspection reports. Precisely when Remy turned the truck over to the insurance company is unclear because discovery in this matter is incomplete. Based on the facts on record, it is clear that the current location and condition of the truck are unknown.

On May 31, 1995, the Nathaniels filed a complaint against Remy. Remy answered, inter alia, that the damages alleged in the complaint were the result of acts or omissions of a third party and that his liability was subordinate to the negligence of that third party. On March 29, 1996, Louis Remy and his wife Madona Remy (together “Remys”) filed a third-party complaint against Ford. The Remys’ third-party complaint alleges that the vehicle Remy was operating at the time of the accident was defective and dangerous. The Remys theorize, inter alia, that the vehicle’s steering and accelerator systems were defectively designed and/or manufactured. On March 24, 2000, the Nathaniels and the Remys, stipulated to the dismissal of the Nathaniels’ action, leaving the Remys as the sole plaintiffs and Ford as the sole defendant in this matter.

On November 18, 1996, Ford sent the Remys its first set of interrogatories and demand for production of documents. When no response to Ford’s discovery requests was forthcoming, Ford’s attorney [145]*145wrote several letters to Plaintiffs, requesting a reply to its discovery requests and attempting to meet and confer to discuss mounting discovery issues. The Remys did not respond. On June 12, 1997, over six months after Ford’s initial requests, the Remys finally responded to Ford’s first set of discovery requests. The Court’s factual analysis is substantially based on these responses because they are the Remys only responses to discovery thus far. On July 11 1997, Ford served the Remys with expert interrogatories and also requested dates to schedule the Remys’ depositions. Over the next three years, the Remys failed to respond to Ford’s expert interrogatories or Ford’s request for depositions, despite correspondence notifying the Remys that their responses to Ford’s expert interrogatories were long overdue. On May 22, 2001, Ford outlined deficiencies within the Remys’ responses to Ford’s first set of interrogatories. The Remys have yet to respond with supplementation or objections to Ford’s initial discovery requests although these interrogatory requests were served on the Remys, over a decade ago, in November of 1996. During the pendency of this litigation the Remys have not requested a single document from Ford. Nor have they propounded a single interrogatory or noticed a single deposition. Finally, on July 29, 2005, Ford filed its Motion to Dismiss for Spoliation of Evidence and Lack of Prosecution that is presently before the court. The Remys’ response to Ford’s Motion to Dismiss was filed almost one year later, on June 6, 2006 utterly out of time and unresponsive to the issues raised in Defendants’ Motion to Dismiss.

II. DISCUSSION

A. Spoliation of Evidence

Spoliation of evidence is “the destruction, or the significant and meaningful alteration of evidence, or the failure to preserve property for another’s use as evidence in pending or reasonably foreseeable litigation.” Byrnie v. Town of Cromwell Bd. Of Edu., 243 F.3d 93, 107 (2d Cir. 2001); Baxt v. Liloia, 714 A.2d 271, 155 N.J. 190, 204, (1998), citing Black’s Law Dictionary 1257 (5th ed.1979). In a civil action spoliation occurs when evidence pertinent to the action is destroyed, thereby interfering with the action’s proper administration and [146]*146disposition.1 Aetna Life and Casualty Co., v. Imet Mason Contractors, 707 A.2d 180, 309 N.J. Super. 358, 364 (App. Div. 1998), citing Hirsh v. General Motors Corp., 628 A.2d 1108, 266 N.J. Super. 222, 234 (1993).

When evidence is spoiled, courts have the authority to impose sanctions. Chambers v. NASCO, Inc., 501 U.S. 32, 43-45, 111 S. Ct. 2123, 115 L. Ed. 2d 27 (1991); Schmid v. Milwaukee Electric Tool Corp., 13 F.3d 76, 79 (3d Cir. 1994); Aetna Life and Casualty Co., 309 N.J. Super. 358, 707 A.2d 180 (1998). Sanctions can include: (1) an adverse inference to be drawn against the spoliator, (2) dismissal with prejudice, or (3) suppression of evidence, Hirsh, 266 N.J. Super at 257. Sanctions imposed by a trial court will not be disturbed on appeal if they are just and reasonable under the circumstances. Aetna Life and Casualty, 309 N.J. Super. at 364. Dismissal, is “normally ordered only when no lesser sanction will suffice to erase the prejudice suffered by the non-delinquent party.” Johnson v. Mountainside Hosp., Respiratory Disease Assoc., 488 A.2d 1029, 199 N.J. Super. 114, 119 (App. Div. 1985), cert. denied, 122 N.J. 188, 584 A.2d 248 (1990). In cases that warrant dismissal, the spoliation has gone to the very foundation of the cause of action, or the party spoiling the evidence has done so deliberately. Abtrax Pharmaceuticals, Inc. v. Elkins Sinn, Inc., 655 A.2d 1368, 139 N.J. 499, 514 (1995).

In Schmid v. Milwaukee Elec. Tool Corp., 13 F.3d 76 (3d Cir.

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Bluebook (online)
48 V.I. 141, 2006 WL 3937343, 2006 V.I. LEXIS 28, Counsel Stack Legal Research, https://law.counselstack.com/opinion/remy-v-ford-motor-co-visuper-2006.