Smith v. Loyd

CourtSuperior Court of Maine
DecidedSeptember 25, 2002
DocketCUMre-01-15
StatusUnpublished

This text of Smith v. Loyd (Smith v. Loyd) 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. Loyd, (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE CUMBERLAND, ss. Cv IL ACTION

ET NO. RE- a): 15 }

si CU 9/95 / a5 (sph.

MILDRED O. SMITH,

Individually and as

Personal Representative of the

Estate of WINFIELD SMITH ORDER ON DEFENDANT’S MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS AND MOTION’ FOR SUMMARY JUDGEMENT

v. DONALD L. GARBRECHT JOHN LOYD, et al. . LAW LIBRARY FACTUAL BACKGROUND? OcT 4 002

The following facts are undisputed: Defendant John Loyd (attorney) represented the Plaintiff Mildred Smith and her late husband Winfield Smith in their personal: ° matters until Mr. Smith’s death in September 1994. The Plaintiff was the sole beneficiary under her late husband’s will. The real estate inherited under the will included three parcels of land on the Mere Point Peninsula in Brunswick, Maine. Only two parcels are at issue in this litigation; both of these parcels are located on the eastern side of Mere Point Road. One parcel has water frontage and an operational boat landing (“Boat Landing”). The second parcel has water views and frontage on Mere Point Road (“MPR Parcel”).

Following Winfield Smith’s death, Plaintiff was in need of financial support and financial planning assistance. The Defendant and the Plaintiff met on several occasions

to discuss how best to ensure her financial security with the estate assets. Included in

' Plaintiffs have moved for voluntary dismissal of Count II as to Defendant Loyd and Count III entirely. Defendant’s Reply Statement of Material Facts does not conform to M.R. Civ. P. 56 (h)(3), which requires a reply to be “limited to any additional facts submitted by the opposing party.” The Plaintiff's additional facts begin at paragraph 49; therefore, only replies to those additional facts are considered for purposes of this motion.

* The third parcel i is on the western side of Mere Point Road and is commonly referred to as the “Family Farm.’ this discussion was the appropriate disposition of the two parcels at issue in this case. The Plaintiff entered into a 99-year lease for the use of the Boat Landing without Defendant’s knowledge. The Plaintiff believed that counsel for the lessee had reviewed the lease documents with Defendant Loyd.

Shortly thereafter, Plaintiff listed the adjacent property, MPR Parcel, for sale with David Gleason, a real estate agent. The MPR parcel was marketed as two separate parcels with a total asking price of $275,000 based upon a market valuation performed by Mr. Gleason. The signature line of the listing agreement did not indicate that Plaintiff was signing in her capacity as Personal Representative.’ Loyd was not aware of the February 10, 1995 listing until after it had been executed.

A new listing agreement was drafted and signed on April 12, 1995, which included both the Boat Landing and the MPR Parcel for a list price of $300,000. That same day an offer was made to purchase the listed property. The next day, April 13, 1995, on her way to sign the purchase and sale agreement (“P&S”), Plaintiff was treated at the hospital for an “attack of nerves.” Later that day Defendant Loyd went to the Plaintiff's home to have her sign the P&S. The Plaintiff signed the new listing agreement and the P&S for the two parcels (the Boat Landing and the MPR Parcel) in her capacity as Personal Representative in the amount of $300,000. After the P&S was executed by the Plaintiff, Defendant Loyd commissioned an appraisal of the entire estate property east of Mere Point Road; on May 10, 1995, Michael Olivo, the appraiser,

reported a value of $250,000 to $270,000.* On June 19, 1995, Defendant Loyd received an

> Plaintiff contends that there was a typographical error and “PR” was omitted. The parties disagree as to why Defendant Loyd was not aware of the listing until after the fact (no notice by Plaintiff; lack of attentiveness on the part of Defendant).

* The circumstances of the appraisal and the direction, if any, given to Mr. Olivo by Defendant Loyd are disputed. offer of $100,000 from the current tenant of the property for the five acres surrounding and including the boat landing.

On July 19, 1996, Plaintiff signed a second amendment to the P&S increasing the sale price to 305,000.° On August 8, 2001, plaintiff commissioned a retroactive appraisal of the property to ascertain its value in 1994. The appraisal determined that as of September 6, 1994 the property was valued at $612,000. This appraisal was commissioned almost six months after the filing of the complaint on February 28, 2001.

Mildred Smith filed a seven-count complaint against Defendant Loyd. Defendant Loyd moves for partial judgment on the pleadings (Counts II and III), and for summary judgment. Plaintiff only opposes the Defendant’s Motion for Summary Judgment on Counts IV (Negligence) and VII (Breach of Fiduciary Duty). The Plaintiff agrees to dismiss the remaining two counts against Defendant Loyd (Count II - Fraudulent Misrepresentation; and Count III - Intentional Infliction of Emotional Distress). For the reasons stated below, Defendant’s Motion is granted as to Count VII and Plaintiff’s request for punitive damages; Defendant’s motion as to Count IV is denied and shall proceed to trial, but not under the theory of negligence resulting from failure to adhere to Maine Probate Code.

DISCUSSION

1. Standing

Defendant asserts that Plaintiff lacks standing to sue as an individual because he never represented her in that capacity. Instead, he asserts that his representation pertained only to her role as the Personal Representative of the Estate of Winfield Smith. The status of a party sufficient to confer standing presents a mixed question of

law and fact. Bissias v. Koulovatos, 2000 ME 189, J 6, 761 A.2d 47, 49. An attorney-

> The first amendment was signed on June 19, 1995, which extended the time to two years for the closing because of the litigation surrounding the long-term lease for the Boat Landing. client relationship is established when “(1) a person seeks advice or assistance from an attorney, (2) the advice or assistance sought pertains to matters within the attorney's professional competence, and (3) the attorney expressly or impliedly agrees to give or

actually gives the desired advice or assistance.” Board of Overseers of the Bar v.

Mangan, 2001 ME 7, ¥ 9, 763 A.2d 1189, 1193 (citations omitted). The parties vehemently disagree as the scope of Defendant Loyd’s representation. Weighing the underlying disputed facts surrounding the extent and purpose of the relationship between Attorney Loyd and Mildred Smith is a task properly left to the fact finder at trial.°

Because it cannot be determined from the record of undisputed facts whether the relationship between Mildred Smith and Attorney Loyd was one of Attorney-Personal Representative and Attorney-Client, or only the former, Defendant’s Motion for Summary Judgment as to Plaintiff’s standing as an individual is denied.

2. Negligence

Plaintiff raises two claims for negligence — professional malpractice and breach of fiduciary duty.

A. Fiduciary Duty

A fiduciary duty is created when “[o]ne standing in a fiduciary relation with

another is subject to liability to the other for harm resulting from a breach of duty

imposed by the relation.” Bryan R. v. Watchtower Bible and Tract Soc’y of New_York,

° Defendant characterizes the “individual suit” as an action by a beneficiary and thus argues that the suit is barred. Nevin v. Union Trust Co., 1999 ME 47, {{ 40-41, 726 A.2d 694, 701 (holding that individual beneficiaries lack standing to assert claims against estate planning attorneys). Defendant’s characterization is incorrect, as is his application of Nevin to the facts in this case.

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Smith v. Loyd, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-loyd-mesuperct-2002.