Woodworth v. Gaddis
2012 ME 138
| Me. | 2012Background
- Woodworth owns land in Steuben; boundary dispute arose from misidentified Robertson boundary lines by Gaddis.
- Crane’s Contract Cutting and Gaddis harvested 17.9 acres on Woodworth’s property based on those erroneous markings.
- Robertson contracted to harvest timber on his property; Crane contracted with Gaddis to identify boundaries.
- Woodworth sued in 2009 for trespass and damages under 14 M.R.S. § 7552, and sought to add Crane as a party; Crane was added once and later sought again.
- Trial court found Gaddis, Crane, and Robertson negligent under § 7552, awarded $67,180 in actual damages, and declined to double damages under § 7552(4)(A).
- On appeal, the court modifies the judgment to double Woodworth’s damages under § 7552(4)(A); denies second motion to add Crane; Robertson’s death does not affect ongoing proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether damages must be doubled under § 7552(4)(A). | Woodworth: negligence triggers mandatory doubling. | Defendants: court interpreted doubling as greater of actual damages or $250. | Doubling mandatory; court erred by not doubling actual damages. |
| Whether regeneration damages under § 7552(3) were properly calculated. | Woodworth: higher regeneration cost estimate should be used. | Court may credit competing estimates; need not adopt higher figure. | Court’s regeneration cost supported by competent evidence; adjustment not required. |
| Whether the trial court abused its discretion in denying Crane’s addition as a party under Rule 21. | Crane should be joined to prevent injustice. | Delay and prejudice; second motion untimely; addition unnecessary. | No manifest abuse; denial within court’s discretion. |
Key Cases Cited
- Hoch v. Stifel, 2011 ME 24 (Me. 2011) (damages review when statutory framework governs restoration value)
- Mehlhorn v. Derby, 2006 ME 110 (Me. 2006) (double damages interpretation under § 7552(4)(A))
- Dupuis v. Soucy, 2011 ME 2 (Me. 2011) (intentional/knowing conduct standard under § 7552(4)(B))
- Handrahan v. Malenko, 2011 ME 15 (Me. 2011) (clear error standard for intentional/knowing conduct)
- Currier v. Huron, 2008 ME 19 (Me. 2008) (damages language interpreted as mandatory; ‘is liable’ language)
- Arrow Fastener Co. v. Wrabacon, Inc., 2007 ME 34 (Me. 2007) (fact-finder weighs competing evidence and credibility)
- Laqualia v. Laqualia, 2011 ME 114 (Me. 2011) (arguments not developed are waived)