Tripping Gnome Farm, LLC v. Ferrara

CourtSuperior Court of Maine
DecidedDecember 2, 2014
DocketCUMre-14-157
StatusUnpublished

This text of Tripping Gnome Farm, LLC v. Ferrara (Tripping Gnome Farm, LLC v. Ferrara) 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
Tripping Gnome Farm, LLC v. Ferrara, (Me. Super. Ct. 2014).

Opinion

ENTERED DEC n 4 201 4

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO. RE-14-157 /_ NM-OttYr)- r"- V;A- IY. TRIPPING GNOME FARM, LLC, RYEN MUNROE, and URSULA MUNROE

Plaintiffs

v.

LOU FERRARA, MELISSA FERRARA, and NEW ENGLAND ALPACAS,

Defendants

Before the court is defendants' motion to stay. There is pending litigation

m the Connecticut Superior Court involving the same parties and issues.

Defendants move the court to stay the proceedings in Maine in favor of the

Connecticut litigation. Defendants argue they cannot obtain complete relief in

Maine. Plaintiffs oppose the motion and argue that because the Maine suit was

filed first, the litigation should take place in Maine. For the following reasons, the

motion to stay is granted.

BACKGROUND

This suit arises out of an agreement between plaintiffs and the defendants

regarding the sale of Tripping Gnome Farm, LLC' s (TGF) alpacas to a third-party

buyer. Plaintiffs do not dispute that TGF agreed to pay and did pay defendants a

commission for alpaca sales in 2011 for brokering a deal between plaintiff and an alpaca buyer. The parties' dispute concerns whether plaintiffs also agreed to pay

"tail commissions" to the defendants, which are fees for future sales of alpacas

between TGF and the third-party buyer. According to defendants, plaintiffs agreed to the terms of a written contract sent to plaintiffs, even though that

contract is unsigned. The contract includes provisions regarding "tail

commissions," selects Connecticut as the forum for litigation, and provides for

attorney's fees to the prevailing party.

Plaintiff TGF filed its complaint for declaratory judgment on April2, 2014,

and an amended complaint was filed on June 12, 2014, which included Ryen

Munroe and Ursula Munroe as plaintiffs. In the amended complaint, plaintiffs

seek the following: in count I, a declaratory judgment that plaintiffs never

agreed to pay defendants the tail commissions; in count II, a declaratory

judgment that plaintiffs did not agree to pay defendants' attorney's fees; in count

III, a declaratory judgment that the parties did not agree to litigate in

Connecticut; and in count IV, a declaratory judgment that plaintiffs Ryen

Munroe and Ursula Munroe cannot be held personally liable in connection with

the dispute between TGF and defendants. In their counterclaim, defendants

allege the following: in count I: breach of contract; and in count II: unjust

enrichment.

Defendants filed a motion to dismiss on June 9, 2014 and argued improper

venue because of the contract's forum selection clause. The court denied the

motion to dismiss on July 3, 2014. Defendants filed the motion to stay on October

17, 2014. The court held a telephone conference with counsel on November 19,

2014 to discuss the motion to stay. A second telephone conference was held on

November 26, 2014 after the Connecticut court .granted the Munroes' motion to

dismiss them as parties in the Connecticut suit.

2 DISCUSSION

A trial court has broad discretion in considering whether to stay a

proceeding when there is litigation pending in another jurisdiction. Fitch v.

Whaples, 220 A.2d 170, 172 (Me. 1966). Although the first-filed action generally

has priority over a subsequent suit filed in another jurisdiction, "[t]he

circumstances of the litigation may be such as to make it desirable to stay the first

action, and to permit the subsequent action to proceed to conclusion." lsi; see

also Tones v. York, 444 A.2d 382, 384 (Me. 1982). In Fitch, the Law Court listed

several factors to guide the trial court in deciding whether to grant a stay:

Multiple considerations may serve the trial court in a judicial exercise of its discretion in granting or denying a stay, such as whether the subsequent action was designed solely to harass the adverse party; the nature of the respective actions, especially with a view as to which appears to provide complete justice; also, where did the cause of action arise and which law will be applicable; will there be great and unnecessary expense and inconvenience; the availability of witnesses; the stage at which the proceedings in the other court have already progressed; the delay in obtaining trial. Each case must perforce present its own variety of circumstances which may necessitate different results.

Fitch, 222 A.2d at 172-73.

In Jones v. York, defendants filed a declaratory judgment action in the

Superior Court shortly before plaintiffs filed a forcible entry and detainer action

in the District Court. 444 A.2d at 384. Nevertheless, the Law Court decided that

although the Superior Court action was filed first, the District Court had

properly taken jurisdiction of the matter. Id. at 385. The court balanced the rights

of the parties and concluded that the summary nature of the District Court

proceedings would give the parties "the just, speedy and inexpensive

determination of their dispute .... " Id.

3 Other jurisdictions "give priority to 'coercive' actions over declaratory

judgment actions or anticipatory suits, regardless of the order of filing." Bluetarp

Fin., Inc. v. Matrix Const. Co., Inc., CUMSC-CV-2012-100, at 5 (Me. Super. Ct.,

Cum. Cnty., Sept. 13, 2012). As one federal court explained, an exception to the

first-filed suit rule "exists where the first-filed suit constitutes an 'improper

anticipatory filing,' or one made under the apparent threat of a presumed

adversary filing the mirror image of that suit in a different [court]." Ontel Prods.,

Inc. v. Project Strategies Corp., 899 F. Supp. 1144, 1150 (S.D.N.Y. 1995). An

anticipatory filing is improper if "it attempts to exploit the first-filed rule by

securing a venue that differs from the one that the filer's adversary would be

expected to choose." Id. "Where a party is prepared to pursue a lawsuit, but first

desires to attempt settlement discussions, that party should not be deprived of

the first-filed rule's benefit simply because its adversary used the resulting delay

in filing to proceed with the mirror image of the anticipated suit." Id.

Based on the correspondence of counsel attached to defendants' reply

memorandum in support of the motion to stay, it appears that defendants waited

to file suit because the parties were engaging in settlement discussions. (Defs.'

Reply Mem. Exhs. A & B.) Before these discussions concluded, plaintiff filed this

suit in Maine. Defendants represent that the Connecticut suit was filed on April

24, 2014, before they were served on May 2 with the summons and complaint for 1 the Maine suit. Based on this timeline, plaintiffs' suit is an anticipatory filing

that should not reap the benefit of the "first-filed" rule.

1 During the telephone conference, plaintiffs' counsel did not dispute defendants' history in the first paragraph of page four of defendants' reply memorandum but offered further explanation and context.

4 Other factors weigh in support of granting a stay. First, if defendants are

correct and the written contract is binding on the parties, the forum selection

clause would apply to the case and the parties would be required to litigate in 2 Connecticut.

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Related

Ontel Products, Inc. v. Project Strategies Corp.
899 F. Supp. 1144 (S.D. New York, 1995)
McCarthy v. U.S.I. Corp.
678 A.2d 48 (Supreme Judicial Court of Maine, 1996)
Fitch v. Whaples
220 A.2d 170 (Supreme Judicial Court of Maine, 1966)
Jones v. York
444 A.2d 382 (Supreme Judicial Court of Maine, 1982)

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