Sleeper v. Lilley

CourtSuperior Court of Maine
DecidedJune 13, 2014
DocketCUMcv-11-006
StatusUnpublished

This text of Sleeper v. Lilley (Sleeper v. Lilley) 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
Sleeper v. Lilley, (Me. Super. Ct. 2014).

Opinion

£ NT ERED JUL 2 8 201.

STATE OF MAINE STATE OF MAINE Cumb!ftand, ss, Clerk's Ofb SUPERIOR COURT CUMBERLAND, ss. CIVIL ACTION JUN 13 2014 Docket No. CV-11-006

RECEIVED mw -CMM-Dbr/3-14- VAUGHN SLEEPER, et al,

Plaintiffs

v. ORDER

DANIEL G. LILLEY, et al,

Defendants

Before the court are two post-trial motions by defendants Daniel G. Lilley and

Daniel G. Lilley Law Offices P.A. (collectively, "the Lilley defendants"): (1) a renewed

motion for judgment as a matter of law pursuant to M.R.Civ.P. SO(b) and (2) a motion

for a new trial and remittitur pursuant to M.R.Civ.P. 59(a).

Judgment was entered on January 6, 2014. The Lilley defendants' motions were

timely filed on January 16. The first round of briefing was completed a month later, but

resolution of the motions was thereafter delayed while portions of the transcript were

ordered. A hearing on the motion was held on May 8, supplemental briefs were filed by

May 16, and the parties have since filed further submissions based on review of the

transcript excerpts that had been obtained.

Legal Principles Applicable to Defendants' Motions

On the Lilley defendants' renewed motion for judgment as a matter of law under

Rule SO(b ), the court must determine "if any reasonable view of the evidence and those

inferences that are justifiably drawn from the evidence supports the jury verdict."

Russell v. Expressjet Inc., 2011 ME 123 '1I 10, 32 A.3d 1030, quoting Madore v. Kennebec Heights Country Club, 2007 ME 92 err 5, 926 A.2d 1180. The court cannot substitute its

judgment for that of the jury. The weighing of evidence, including the credibility of

witnesses, is reserved to the jury. Wood v. Bell, 2006 ME 98 err12, 902 A.2d 843.

On the motion for a new trial, the Lilley defendants must establish that it is

reasonably clear that prejudicial error has been committed or that substantial justice has

not been done. Davis v. Currier, 1997 ME 199 err 7, 704 A.2d 1207. This standard is not

intended to allow a trial judge to substitute his or her view of the evidence for the

decision of the jury. Chenell v. Westbrook College, 324 A.2d 735, 737 (Me. 1974). The Lilley

defendants' new trial motion relies primarily on alleged errors in the admission of

evidence and in the conduct of the trial that allegedly prejudiced the jury.

Arguments Raised

At the outset the court notes that lengthy portions of the legal memoranda

submitted by the Lilley defendants on their post-trial motions consist of attempts to

reargue the evidence. Whatever the merits of those arguments, they either were or

should have been presented to the jury. Neither Rule 50(b) nor Rule 59(a) offers any

relief to the extent that the jury found against the Lilley defendants on the evidence.

Moving beyond the Lilley defendants' effort to reargue the evidence, the court

finds that a number of their arguments are without merit,l Nevertheless, the court

1 Specifically, the record does not support the Lilley defendants' contention that the Sleepers' expert did not offer an adequate opinion that the Lilley defendants were negligent in handling the liED claim and does not support the Lilley defendants' contention that they were not informed that the court's instruction that the jury could not consider the Sleepers' estimate of the fair market value of their farm or the McCausland damage figure would be given orally rather than as part of the written instructions. In addition, the court sees no basis on which to order remittitur on the Lilley defendants' claim that the damages awarded were excessive. Under the court's instructions, all but $30,000 of the jury award constituted an award for emotional distress, and the court has no principled basis to reduce the jury's evaluation of emotional distress. Finally, the court does not find any adequate basis to disturb the jury's finding that the Lilley defendants were professionally negligent.

2 concludes that the following issues raised by the Lilley defendants require further

discussion:

(1) whether there was sufficient evidence to allow the jury to decide the claim that, absent malpractice by the Lilley defendants, the Sleepers would likely have prevailed on their tortious interference claim before the arbitrator;

(2) whether there was adequate evidence to support the damages claimed on the tortious interference claim;

(3) whether, given the court's summary judgment ruling, the Sleepers should have been allowed to proceed at trial on the claim that, absent malpractice by the Lilley defendants, the Sleepers would likely have prevailed on their IIED claim before the arbitrator;

(4) whether there was sufficient evidence to allow the jury to decide the claim that, absent malpractice by the Lilley defendants, the Sleepers would likely have prevailed on their IIED claim before the arbitrator;

(5) whether the court erroneously excluded certain evidence that the Lilley defendants wished to offer on the IIED issue and that might have been considered by the jury on both IIED and on the tortious interference issue;

(6) whether the Sleepers' estimate of the fair market value of their farm and the McCausland damage calculation worked up for purposes of the arbitration improperly influenced the jury notwithstanding the court's instruction that the jury could not consider those figures as evidence of damage;

(7) whether the court's instruction as to the weight to be given to expert testimony was erroneous;

(8) whether under Steeves v. Bernstein, Shur, Sawyer & Nelson, 1998 ME 210 <[<[ 17- 18, 718 A.2d 186, plaintiffs should not have been entitled to a jury on the question of whether the Sleepers would have prevailed before the arbitrator and the amount of any damage award.

By way of background in considering the above subjects, it should be noted that

the trial was significantly affected by scheduling issues. Counsel for both parties

originally estimated that, with the jury already picked, the case could be tried to a

verdict in four or five days. The case was therefore scheduled to begin on December 16.

In retrospect this was an ill-advised decision given the nature and complexity of the

3 case. As issues arose and the case bogged down, it became clear that the trial was going

to run over into the Christmas week, and the parties and the court began rushing to try

to get the case to the jury before the Chrisbnas holiday.

At a certain cost, that objective was achieved? However, the rush to finish the

case prevented the court and the parties from taking the time that should have been

allowed to consider certain issues and make an adequate record. The looming

Christmas holiday contributed to some of the problematic rulings and the resulting

prejudice outlined below.

Tortious Interference Claim

The Sleepers' tortious interference claim depended on Ronald Barnes's testimony

that he attended a meeting between Agway and the pool growers at which Agway

"recommended" that the pool growers not purchase potatoes from Sleeper Farms.

Barnes testified that the "general consensus" he took away from the meeting was that if

he purchased seed from the Sleepers, "it would have consequences for marketing my

crop the following year." He could not say what Agway had said that left him with that

impression.

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Sleeper v. Lilley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sleeper-v-lilley-mesuperct-2014.