Estate of Hoch v. Stifel
16 A.3d 137
| Me. | 2011Background
- Hoch, a Maine resident and physician, had substantial US assets; Chandler POA allowed managing Hoch's affairs in Maine.
- Chandlers sued the Stifels in Maine over undue influence and asset extraction after Hoch resided at the Stifel facility in Maine.
- Stifels challenged jurisdiction, venue, and discovery obligations; Hoch died during the proceedings (June 24, 2008).
- Chandlers obtained interim relief (TRO) and discovery orders; Stifels defaulted on contempt and discovery obligations.
- Post-death, Hoch's German will purportedly left the Stifels as heirs; court ultimately awarded compensatory and punitive damages and imposed a constructive trust on assets.
- Final judgment was entered September 25, 2009; compensatory damages were reduced due to valuation adjustments, with punitive damages upheld at $3,000,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Maine has personal jurisdiction over the Stifels | Hoch's Maine assets and Chandler POA create long-arm reach | No sufficient contacts; process not fair | Yes; Maine has personal jurisdiction under 704-A and due process. |
| Whether Franklin County was proper venue | Venue appropriate given assets and witnesses in Maine | Venue improper; forum non conveniens | Waived; court ruled on forum non conveniens grounds. |
| Whether default for discovery violations was appropriate | Noncompliance harmed administration of justice | Stifels acted on Hoch's wishes and German counsel advice | Yes; sanctions and default judgment appropriate. |
| Whether post-death transfers could be used to prove damages | Damages flow from pre-death conduct; post-death transfers admissible | Post-death assets not properly tied to claims; German assets outside Maine | Admissible; compensatory damages supported with adjustment to valuation. |
| Whether punitive damages were properly awarded and amount reasonable | Malice proven; amount warranted | Amount excessive given wealth and deterrence | Upheld; $3,000,000 award affirmed; ratio considered reasonable. |
Key Cases Cited
- McAlister v. Slosberg, 658 A.2d 658 (Me. 1995) (default allegations treated as facts on review of default)
- Harris v. Soley, 2000 ME 150 (Me. 2000) (sanctions for discovery violations and default judgments carefully reviewed)
- Shrader-Miller v. Miller, 2004 ME 117 (Me. 2004) (punitive damages review; ratio considerations)
- Rand v. Bath Iron Works Corp., 2003 ME 122 (Me. 2003) (state interest and deterrence in punitive awards)