Reo Marine, Inc. v. Johnson

Superior Court of Maine·Decided July 19, 2021·No. CUMcv-20-549·Unpublished

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.

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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.

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

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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.

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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.

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

The repairs that Reo Marine now claims constituted spoliation were performed for Johnson by a person named Mike Kelly in early June of 2021. The exact dates of the repairs are not revealed by the record but there is no evidence that they were performed prior to June 5 - the date set forth in counsel's Mai·ch 16 letter as the end date of the period in which Johnson was instructed that no repairs should be performed.

With its motion Reo Marine has submitted an affidavit by its proposed expert witness that essentially says that the June 2021 repairs pe1formed by Kelly have eliminated any alleged dainage that may have existed. As a result, with one exception, 5 he states that he is unable to offer any opinion as to that damage, as to the cause and effect of that damage, and as to the repairs originally performed by Reo Marine.

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

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