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lawsuitdefendantdamagesnegligencetrialtestimonymotionexpert witnessjury instructions
defendantdamagestrialtestimonymotionexpert witnessjury instructions

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Bratton v. McDonough, 91 A.3d 1050, 2014 ME 64

Facts

In September 2004, the Brattons moved into a rental property owned by McDonough, where their children were later found to have elevated blood lead levels. Despite testing positive for lead, McDonough dismissed their concerns and attributed the lead to external sources. In 2008, the Department of Health intervened, confirming lead hazards in the home and mandating the Brattons' relocation, which was delayed by McDonough's refusal to cooperate. The Brattons filed a lawsuit in 2009 alleging negligence and emotional distress due to the lead exposure.

In September 2004, the Brattons moved into a rental property owned by McDonough, where their children were later found to have elevated blood lead levels. Despite testing positive for lead, McDonough dismissed their concerns and attributed the lead to external sources.

Issue

Did the trial court err in excluding expert testimony, granting judgment as a matter of law on certain claims, and failing to provide proper jury instructions regarding causation and damages?

Did the trial court err in excluding expert testimony, granting judgment as a matter of law on certain claims, and failing to provide proper jury instructions regarding causation and damages?

Rule

The court must view evidence in the light most favorable to the non-moving party when considering a motion for judgment as a matter of law, and the burden of proving independent causation lies with the defendant.

The court must view evidence in the light most favorable to the non-moving party when considering a motion for judgment as a matter of law, and the burden of proving independent causation lies with the defendant.

Analysis

The Supreme Judicial Court found that the trial court had made clear errors by excluding the testimony of qualified expert witnesses on causation and by failing to instruct the jury that the burden of apportioning damages to independent causes rested with the landlord. The court emphasized that the evidence presented could support a finding of negligence and emotional distress, which should have been determined by a jury.

The Supreme Judicial Court found that the trial court had made clear errors by excluding the testimony of qualified expert witnesses on causation and by failing to instruct the jury that the burden of apportioning damages to independent causes rested with the landlord.

Conclusion

The Supreme Judicial Court vacated the judgment and remanded the case for a new trial, stating that the trial court's errors had materially prejudiced the Brattons.

The Supreme Judicial Court vacated the judgment and remanded the case for a new trial, stating that the trial court's errors had materially prejudiced the Brattons.

Who won?

Halsey McDonough prevailed in the initial trial, but the Supreme Judicial Court's ruling vacated that outcome, indicating that the Brattons were entitled to a new trial due to the trial court's errors.

Halsey McDonough prevailed in the initial trial, but the Supreme Judicial Court's ruling vacated that outcome, indicating that the Brattons were entitled to a new trial due to the trial court's errors.

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