Bridge Tower Dental, P.A. v. Meridian Computer Center, Inc.
152 Idaho 569
| Idaho | 2012Background
- Bridge Tower hired Meridian Computer Center in 2003 under a warranty to provide a computer system with data stored on two mirrored hard drives and a backup system; Colson was the Bridge Tower liaison and maintenance provider.
- In June 2005 Meridian, under repair for a suspected failing hard drive, took the server and both drives; Patten supposedly would diagnose/replace and Colson asked for a data backup before any destructive work, which Patten disputes having been requested.
- Patten performed a low-level format to the failing drive, installed a new drive, and inadvertently mixed up the source and destination drives, erasing all data on the mirrored drive and destroying Bridge Tower’s data without backups.
- Bridge Tower alleged breach of contract and negligence (bailment law) after the data loss; the district court instructed the jury on a combined theory and Meridian won a general verdict in 2010.
- Bridge Tower challenged the verdict via motions for JNOV and New Trial; Meridian sought attorney’s fees and costs under Idaho Code § 12-120(3), which the district court granted.
- This Court reverses on the JNOV issue, vacates the attorney’s-fees award to Meridian (finding Meridian is not the prevailing party), and remands for entry of a JNOV in Bridge Tower’s favor on liability and damages proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether Meridian proved non-negligence in data loss | Bridge Tower | Meridian | JNOV reversed; burden shows negligence not proven; Meridian failed to prove lack of negligence |
| whether jury instructions properly reflected bailment law | Bridge Tower | Meridian | No need to resolve; Court found JNOV warranted, rendering this issue moot |
| whether Meridian's fee award under § 12-120(3) was proper | Bridge Tower | Meridian | Fee award vacated; Meridian not prevailing party; costs on appeal awarded to Bridge Tower |
Key Cases Cited
- Loomis v. Imperial Motors, Inc., 88 Idaho 74 (1964) (bailee must exercise reasonable care over bailed property)
- Low v. Park Price Co., 95 Idaho 91 (1972) (presumption of negligence against bailee when damaged on return; burden to show lack of negligence)
- Compton v. Daniels, 98 Idaho 915 (1978) (bailee bears burden of persuasion to show non-negligence; otherwise bailor entitled to judgment)
- Bratton v. Scott, 150 Idaho 530 (2011) (standard for reviewing JNOV appeal; abuse of discretion for new trials)
- Schmechel v. Dillé, 148 Idaho 176 (2009) (new trial discretion and prejudicial legal errors warrant new trials)
- Dyet v. McKinley, 139 Idaho 526 (2003) (discretionary standard for trial rulings and error correction on appeal)
- O'Connor v. Harger Constr., Inc., 145 Idaho 904 (2008) (discretionary review standards and evidentiary sufficiency considerations)
- City of McCall v. Buxton, 146 Idaho 656 (2009) (broad interpretation of commercial-transactions for § 12-120(3) purposes)