Reo Marine, Inc. v. Johnson

CourtSuperior Court of Maine
DecidedJuly 19, 2021
DocketCUMcv-20-549
StatusUnpublished

This text of Reo Marine, Inc. v. Johnson (Reo Marine, Inc. v. Johnson) 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
Reo Marine, Inc. v. Johnson, (Me. Super. Ct. 2021).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. CV-20-549

REO MARINE, INC.,

Plaintiff

V. ORDER

KENNETH JOHNSON

Defendant and Counterclaim-Plaintiff

V.

RICHARD REO,

Additional Party on Counterclaim

Before the court is a motion by Rea Marine Inc. and Richard Rea (refened to collectively

as Reo Marine) to strike the counterclaims asserted by Kenneth Johnson. Rea Marine asserts

that Johnson's counterclaim should be dismissed based on the doctrine of spoliation - because

Johnson had repairs performed before Rea Marine' s expert examined the alleged damage which

forms the basis of Johnson's counterclaims.

This action arises from the hauling, winter storage, and relaunching by the Reo Marine

boatyard of a trawler named "Serenity" that is owned by Johnson.

Reo Marine alleges that although it stored and launched Johnson's trawler in 2019-20,

Johnson has not paid Reo Marine for its services and for repairs performed by Reo Marine to the

keel of the trawler. Rea Marine further alleges that when it launched the trawler on July 2, 2020,

Johnson tendered Reo Marine a check to pay Reo Marine but stopped payment on that check

before it cleared. (

For his part, Johnson alleges that the damage to the keel of the trawler was the fault of

Reo Marine and was caused when the trawler was hauled in November 2019. 1 He further alleges

that Richard Reo promised to repair the keel at Reo Marine's expense. Nevertheless, Johnson

alleges, when it came time to launch the trawler on July 2, 2020, Reo Marine presented a bill for

the keel repairs as well as for the winter storage and refused to launch the trawler until Johnson

paid for the keel repairs, as well as for winter storage and certain other costs.

Johnson's counterclaims further allege that the repairs performed by Reo Marine were

defective, and he seeks compensation for damage to the trawler due to Reo Marine's alleged

failure to adequately repair the damage it had caused. Answer and Amended Counterclaim ~~ 46­

47. It appears that the damages sought by Johnson on this claim dwarf the dispute between the

parties with respect to storage fees and the amount originally billed for repairs, and it is this

claim that is the subject of Reo Marine's motion to strike.

Reo Marine's motion is denominated as a motion to strike or in the alternative to dismiss

but does not cite any specific rule of civil procedure. The court considers Reo Marine's motion

as a request for discovery sanctions. At oral argument on June 23, counsel for both parties

confirmed that all the relevant communications between the parties had been provided to the

court and agreed on the timeline set forth below.

At the outset, although Reo Marine's motion 1s addressed to all of Johnson's

counterclaims, it really only applies to Johnson's claims that Reo Marine's repairs were defective

- an aspect of Johnson's alleged damages on count I of his counterclaims (breach of contract)

and the damages sought on count II of his counterclaims (negligence). Counts III, IV, and V of

Johnson's counterclaims instead relate to the dispute between the parties as to whether Reo

1 Specifically, by "excessive point loading" in the manner in which the hull was positioned on blocks

after being hauled from the water.

2 promised to repair damage allegedly sustained when the trawler was hauled in the fall of 2019 at

Reo Marine's expense.

Discussion

The parties agree that the Law Court has not addressed the criteria for applying the

doctrine of spoliation in civil cases. Where evidence has been destroyed or otherwise made

unavailable by actions of a party to litigation, the First Circuit and several Superior Court

decisions have focused on two factors: (I) the degree of prejudice to the non-offending party and

(2) the degree of fault of the non-offending party. See, e.g., Collazo-Santiago v. Toyota Motor

Corp., 149 F.3d 21, 29 (1st Cir. 1998). The issue of prejudice is afforded more weight, and

imposition of a spoliation sanction is designed to prevent the non-offending party from

suffering "unfair prejudice." Sacramona v. Bridgestone/Firestone, Inc., 106 F.3d 444, 446 (1 51

Cir. 1997).

The spoliation issue in this case arises from the fact that, while there was a dispute as to

financial responsibility for Reo Marine's repairs, Johnson apparently did not asse1i that the 2 repairs had also been defective until after the trawler had been hauled in the fall of 2020.

Johnson provided an expert report to Reo Marine in the fall of 2020 but that report3 stated that a

more detailed examination with bottom paint removed would be necessary. Counsel and perhaps

other representatives of Reo Marine inspected the trawler at that time and photographs were

2 Submissions by Reo Marine suggest that there is a counterargument that any damage to the trawler apparent in the fall of2020 occurred while it was being operated during the summer of 2020, after it had left Reo Marine.

3 A copy of that report, as updated in March 2021, is contained in the court's file.

3 (

taken and are available. 4 However, Johnson's expe1i report was incomplete at that time, and

presumably for that reason Reo Marine did have an expert inspect the trawler in the fall of 2020.

Reo Marine's claim of spoliation arises from the fact that in March of 2021 counsel for

Johnson advised counsel for Reo Marine that the bottom paint had been removed and Johnson

intended to have repairs performed before the trawler was launched in the spring of 2021.

Johnson's counsel suggested that ifReo Marine wanted to have an expert inspect the trawler, that

should occur before April 16, 2021. Counsel for Reo Marine immediately wrote back to say that

Reo Marine did not consent to having any repairs performed without a court order, noting that

the supplemental report from Johnson's expert had not been received.

The next day, however, counsel for Reo Marine modified his position to state that

Johnson should not make any repairs to the part of the trawler allegedly damaged and improperly

repaired by Reo Marine "between now and June 5111, 2021" unless Reo Marine consented or

Johnson obtained leave of court. Letter of March 16, 2021 emailed to counsel for Johnson (Ex.

BA3- to Bond affidavit) (emphasis added).

On the same date counsel for Reo Marine emailed counsel for Johnson to propose that

Reo Marine expert inspect the trawler on Monday March 22. Counsel for Johnson responded that

she had an all-day mediation on March 22 and suggested late afternoon on March 23, 24, or 26.

(Ex. BA4 to Bond affidavit).

The record does not contain any further communications between counsel on scheduling

an inspection by Reo Marine' s expert. It appears instead that counsel for Reo Marine began

focusing on other issues between the parties. It was not disputed at the June 23 argument that the

4 At oral argument on June 23, counselfor Reo Marine acknowledged that representatives ofReo Marine may have had some oppotiunity in the fall of2020 to inspect the trawler after bottom paint had been removed.

4 final report by Johnson's expert (updated on March 10, 2021) was provided sometime in March

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

Related

Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Maine Family Federal Credit Union v. Sun Life Assurance Co.
1999 ME 43 (Supreme Judicial Court of Maine, 1999)
Coffin v. Dodge
76 A.2d 541 (Supreme Judicial Court of Maine, 1950)
Bisson v. HANNAFORD BROTHERS COMPANY, INC.
2006 ME 131 (Supreme Judicial Court of Maine, 2006)
Potter, Prescott, Jamieson & Nelson, P.A. v. Campbell
1998 ME 70 (Supreme Judicial Court of Maine, 1998)
Oceanside at Pine Point Condominium Owners Ass'n v. Peachtree Doors, Inc.
659 A.2d 267 (Supreme Judicial Court of Maine, 1995)
Mahar v. StoneWood Transport
2003 ME 63 (Supreme Judicial Court of Maine, 2003)
Tucker J. Cianchette v. Peggy A. Cianchette
2019 ME 87 (Supreme Judicial Court of Maine, 2019)
Kenny v. Department of Human Services
1999 ME 158 (Supreme Judicial Court of Maine, 1999)
Ramsey v. Baxter Title Co.
2012 ME 113 (Supreme Judicial Court of Maine, 2012)
King v. Greenblatt
149 F.3d 9 (First Circuit, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
Reo Marine, Inc. v. Johnson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reo-marine-inc-v-johnson-mesuperct-2021.