Smith v. Cent. Maine Power Co.

CourtSuperior Court of Maine
DecidedNovember 14, 2008
DocketPENcv-07-174
StatusUnpublished

This text of Smith v. Cent. Maine Power Co. (Smith v. Cent. Maine Power Co.) 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
Smith v. Cent. Maine Power Co., (Me. Super. Ct. 2008).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, ss Docket No. CV-OY-174 '.. r:'!,./,/ - \ '~i r.""" l[ ()

, I

BRYAN A. SMITH,

Plaintiff

v. FINDINGS AND CONCLUSIONS

CENTRAL MAINE POWER ­ ,..-----". .. _-_. COMPANY, FILED & ENTERED SUPERIOR COURT Defendant NOV 06 2008

PENOBSCOT COUNTY

BACKGROUND

Before the Court is a Complaint brought July 11, 2007 by Bryan A. Smith against

Central Maine Power Company (CMP). It alleges that CMP negligently caused personal

injuries to Mr. Smith due to CMP's failure to adhere to minimum height requirements for

the 19.9 kV electrical distribution line located along the westerly side Route 166 in the

Town of Penobscot, Maine. Mr. Smith sustained severe electrical injuries while

"unstepping" a mast on a sailboat on October 31, 2002. At the time of the accident, Mr.

Smith was employed by Devereaux Marine, a boatyard whose operations include

launching, hauling, repairing, and storing privately owned boats, primarily sailboats.

CMP answered the Complaint on July 20, 2007, denying the allegations. It also

asserted affirmative defenses, including comparative negligence, and the allegation that

1 Mr. Smith's injuries "were caused or contributed to by others," thus absolving CMP of

any liability.

Mr. Smith is represented by Attorney Barry Mills and Attorney Lisa Cohen Lunn.

CMP is represented by Attorney Mark Dunlap. The matter was tried before this Court

beginning July 8, 2008. The parties submitted written closing arguments in rnid­

September of2008. Although expected, rebuttal arguments were not filed by either party.

The Court has considered the testimony of all witnesses at trial, as well as

testimony submitted by way of depositions, all exhibits from the parties, and their closing

arguments. The Court also reviewed the legal arguments made by the parties as to

Defendant's Second Motion in Limine which dealt with the "sole proximate cause" issue,

as well as arguments made by the parties as to the Defendant's first Motion in Limine and

Motion for Partial Motion for Summary Judgment. The Court has also reviewed the

applicable provisions of the National Electrical Safety Code (Def. Exh. 1), PUC Chapter

910, the Maine Overhead High Voltage Line Safety Act, 35-A MRSA §101 et seq, and

applicable case law.

FINDINGS AND CONCLUSIONS

35-A MRSA §103 et seq establishes and governs the authority of the Public

Utility Commission to regulate utilities, including Central Maine Power. Section l04

states as follows: "The provisions of this Title shall be interpreted and construed liberally

to accomplish the purpose of this Title. The Commission has all implied and inherent

2 powers under this Title, which are necessary and proper to execute faithfully its express

powers and functions specified in this Title.

Section 101 of Title 35-A reads as follows:

The purpose of this Title is to ensure that there is a regulatory system for public utilities in the State which is consistent with the public interest and with other requirements of law. The basic purpose of this regulatory system is to assure safe, reasonable and adequate service at rates which are just and reasonable to customers and public utilities.

35-A MRSA §1501 provides that a public utility which violates, or causes or

permits a violation of this Title, may be liable in damages to a person injured as a result

of the violation.

In addition, it has long been the law in Maine that a public utility in Maine is

subject to legal principles which govern the law of negligence. In Fitts v. Central Maine

Power, 562 A,2d 690 (Me. 1989) the Maine Supreme Court held that an electric utility is

"bound to exercise due care and diligence." [Citing Edwards v. Cumberland County

Power and Light Co., 146 A, 700 (Me. 1929)]. In Fitts, the Court also stated that the

standard of care for a utility is "such care as an ordinarily reasonable and prudent person

would have exercised under like circumstances." [Citing O'Brien v. JG. White & Co.,

Inc., 128 Me. 207]. Thus, consumers of electricity in Maine are entitled to the "assurance

of a reasonable degree of safety." Id. at 212.

The Plaintiff argues that CMP was negligent because it violated PUC regulations

governing vertical height clearances, deviated from its own internal safety policies, and

failed to adequately train its employees in the application of those policies.

The Defendant's primary defense is that the PUC regulations relied upon by the

Plaintiff are not applicable to the power lines on Route 166. In addition, the Defendant

3 argues that Devereaux Marine's negligence was the sole proximate cause of Bryan

Smith's injuries. 1 In this regard, the Defendant relies on provisions of the Maine High

Voltage Wire Safety Act (MHVWSA) and OSHA standards which require a ten foot

setback, and notification to the utility, if work is done in close proximity to power lines.

The Defendant also claims that Devereux Marine negligently failed to train its employees

regarding working safely near power lines.

CMP's Internal Waterway Clearance Standard

The parties expended much effort in debating whether Table 232-1(8) of the

National Electrical Safety Code, and Chapter 910 of CMR 65-407 apply to the power

lines in issue. If those regulations apply, CMC would be in violation of height

requirements imposed by Maine law, and under 35-A MRSA §1501, CMP could be liable

to Bryan Smith for injuries caused by any such violations.

Before determining whether those regulatory provisions apply to the power lines

at Devereaux Marine, the Court finds that CMP violated its own standard for vertical

clearances for these power lines. That standard is similar, although not identical, to the

NESC standards found in paragraph 8 of Table 232-1. Defendant's Exhibit 30, which was

admitted by agreement, requires a 45.5 vertical clearance for these power lines. The

parties agree that their actual height was approximately 30 feet from the ground.

Gary Ricci, who has worked for CMP for over 30 years, has been responsible for

the design and planning of CMP distribution standards since 2001. He referred to

I The parties agree that Mr. Smith's exclusive remedy against Devereaux Marine is pursuant to the Maine Workers Compensation Act. The parties also stipulated that as of June 24, 2008, Maine Employer's Mutual Insurance Company (MEMIC) has paid a total of $26 I, 3 I 5. 70 on this claim.

4 Defendant's Exh. 30 as a "construction standard," and it was also referred to as

"Construction Standard 305-11." Mr. Ricci testified that the National Electrical Safety

Code standards are incorporated into his "standards book" which contains this standard.

He was asked by CMP's attorney what standard would control if there was a difference

between an NESC standard and a CMP standard, and Mr. Ricci indicated that there

would be no difference. The parties seem to agree that this standard was in effect within

the company at the time of the accident.

The internal CMP standard at issue requires a 45.5 foot vertical clearance in

"areas used for rigging and launching sailboats." The Court finds that the boatyard at

Devereaux was, at the time of this accident, such an area. The Court bases this on the

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Related

Toomey v. Town of Frye Island
2008 ME 44 (Supreme Judicial Court of Maine, 2008)
Edwards v. Cumberland County Power & Light Co.
146 A. 700 (Supreme Judicial Court of Maine, 1929)
Fitts v. Central Maine Power Co.
562 A.2d 690 (Supreme Judicial Court of Maine, 1989)
Bukowski v. Geo. A. Hormel & Co.
157 F.R.D. 50 (S.D. Iowa, 1994)

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