Village of Big Bend v. Anderson

308 N.W.2d 887, 103 Wis. 2d 403, 1981 Wisc. App. LEXIS 3326
CourtCourt of Appeals of Wisconsin
DecidedJune 10, 1981
Docket80-1472
StatusPublished
Cited by24 cases

This text of 308 N.W.2d 887 (Village of Big Bend v. Anderson) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Village of Big Bend v. Anderson, 308 N.W.2d 887, 103 Wis. 2d 403, 1981 Wisc. App. LEXIS 3326 (Wis. Ct. App. 1981).

Opinion

BROWN, J.

The primary issue on this appeal is whether a party in a civil case may obtain a reversal of an adverse judgment on the grounds of ineffectiveness of counsel at trial. We conclude an aggrieved party’s remedy does not lie against the opposing party in the civil suit but rather should be sought in a malpractice action against the allegedly incompetent attorney. We also find the trial court’s findings are supported by sufficient evidence and accordingly affirm the judgment.

This case arises out of a contract dispute between the Village of Big Bend and John U. Anderson. On January 5, 1978, the village conveyed to Anderson a parcel of property for construction of an industrial building. The contract contained the following language:

Village has the right to rescind the sale and repurchase this lot at 75% of the sale price in the event an industrial building is not constructed on said lot within one year of the date the lot is finally purchased.

Anderson failed to build within the one year period. The village notified Anderson that it intended to exercise its option to repurchase the property. This action was commenced May 16, 1979. Several attempts to reach a negotiated settlement were made during the course of the litigation. The dispute was discussed at the April 3, 1980 village board meeting. The official minutes read:

Mr. Anderson’s Attorney said they would pay the $2,500.00 and complete the building by Aug. 31. Matter to be settled later.

A building permit was thereafter issued and construction began. However, a final settlement was never reached. The permit was later rescinded and construction ceased.

*405 On July 21, 1980, a trial was held to the court which resulted in a judgment in favor of the village. On appeal, Anderson points out several instances of alleged incompetence of his trial counsel which he argues “reduce [d] the trial to a farce and a mockery of justice.” 1 He contends his representation was so ineffective as to constitute a denial of due process of law. Therefore, he contends that the judgment should be reversed.

Initially, it must be emphasized that this is not a criminal action. A defendant in a criminal prosecution is guaranteed assistance of counsel for his defense. U.S. Const. amend. VI; Wis. Const. art. I, §7. See also Powell v. Alabama, 287 U.S. 45 (1932). Legal representation in a criminal matter “must be equal to that which the ordinarily prudent lawyer, skilled and versed in criminal law, would give to clients who had privately retained his services.” State v. Harper, 57 Wis.2d 543, 557, 205 N.W.2d 1, 9 (1973). Representation falling below that standard may be grounds for a reversal.

A civil suit presents far different considerations. There is no express constitutional guarantee of representation by counsel in a civil matter. Unlike many criminal defendants who are represented by court-appointed counsel, parties in a civil action retain the counsel of their choice. In a criminal case, a defendant’s liberty is at stake, and the prosecutorial force of the state is involved. While potentially involving large sums of money, a civil matter is not penal in nature, and the state is generally not directly involved. 2 Despite these distinct *406 characteristics, Anderson urg'es this court to define a minimum standard in the civil arena similar to that established for a criminal matter. We decline to do so.

His rights, however, may be vindicated in a different fashion so as not to prejudice the village. For instance, in Link v. Wabash Railroad, 370 U.S. 626 (1962), the petitioner sought reversal of an order dismissing his complaint after his counsel failed to appear for a scheduled pretrial conference. The Supreme Court affirmed the dismissal stating:

Petitioner voluntarily chose this attorney as his representative in the action, and he cannot now avoid the consequences of the acts or omissions of this freely selected agent. Any other notion would be wholly inconsistent with our system of representative litigation, in which each party is deemed bound by the acts of his lawyer-agent ....

Id. at 633-34. Then, in a footnote, the Court considered the equitable impact of its ruling:

[I]f an attorney’s conduct falls substantially below what is reasonable under the circumstances, the client’s remedy is against the attorney in a suit for malpractice. But keeping this suit alive merely because plaintiff should not be penalized for the omissions of his own attorney would be visiting the sins of plaintiff’s lawyer upon the defendant. [Emphasis omitted.]

Id. at 634, n. 10. See also Universal Film Exchanges, Inc. v. Lust, 479 F.2d 573, 577 (4th Cir. 1973); Schwarz v. United States, 384 F.2d 833, 835-36 (2d Cir. 1967).

We adopt the Link rationale that the client’s remedy in a civil case is a suit for malpractice. A civil litigant whose rights have been adversely affected by a negligent attorney may hold that attorney liable for any monetary losses caused by the negligence. Adequate compensation *407 may be measured in dollars and cents. A criminal defendant represented by an incompetent attorney cannot be compensated monetarily. Therefore, his or her sole remedy lies in an attack on the merits of the conviction.

There are other remedies available. This court may, if the case demands it, reverse a trial court’s determination under sec. 752.35, Stats. 3 If the trial record reveals an egregious example of incompetent counsel, we may, “to accomplish the ends of justice,” order a discretionary reversal. Id. The standard of review is whether the evidence and the law are such that the losing party “probably should have won and should therefore be given another chance.” Sentell v. Higby, 87 Wis.2d 44, 50, 273 N.W.2d 780, 783 (Ct. App. 1978). It is conceivable that such a case might arise due to extreme attorney negligence. This case, however, does not meet the strict standard for a discretionary reversal.

This is not to say that parties must wait until a proceeding is completed to protect themselves from an incompetent attorney. A trial judge has a duty to protect the rights of the litigants in his or her court. As was stated in Ennis v. Ennis, 88 Wis.2d 82, 97, 276 N.W.2d 341, 347 (1979):

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Bluebook (online)
308 N.W.2d 887, 103 Wis. 2d 403, 1981 Wisc. App. LEXIS 3326, Counsel Stack Legal Research, https://law.counselstack.com/opinion/village-of-big-bend-v-anderson-wisctapp-1981.