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Keywords

tortdefendantdamagesnegligenceliabilityappealtrialstrict liability
plaintiffdefendantdamagesnegligenceliabilityappealtrialstrict liabilitycommon law

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Byram v. Main, 523 A.2d 1387

Facts

Ray Byram owned a tractor-trailer rig that struck a pet donkey named Meadow, owned by Peter Main's daughter, after the donkey escaped its enclosure and wandered onto Interstate 95. Following a jury-waived trial, the Superior Court found Main strictly liable for the damages caused to Byram's rig. Byram had amended his complaint to include a strict liability count after an earlier appeal, where the court had determined that the negligence claim should not have been dismissed. The case was then brought back to the Supreme Judicial Court for further review.

Defendant Peter Main appeals from a judgment entered on August 22, 1986, by the Superior Court (Penobscot County) in the amount of $27,483.52 for plaintiff Ray Byram. After a jury-waived trial the court found Main strictly liable for damages to Byram's tractor-trailer rig caused in the early morning hours of July 22, 1981, when Byram's rig struck Meadow, the pet donkey of Main's daughter, which had escaped from its enclosure and wandered onto Interstate 95 in Orono.

Issue

Whether the owner of a domestic animal that has escaped and wandered onto a high-speed public highway is strictly liable for harm resulting from a motor vehicle's collision with that animal.

The sole issue presented by this second appeal is whether the owner of a domestic animal that has escaped and wandered onto a high-speed public highway is strictly liable for harm resulting from a motor vehicle's collision with that animal.

Rule

The court adopted the rule of liability set forth in the Restatement (Second) of Torts § 518, which states that except for animal trespass, a possessor of a domestic animal that is not known to be abnormally dangerous is liable for harm done only if he intentionally causes the harm or is negligent in failing to prevent it.

We, as does the Restatement, leave the highway traveler who is injured by colliding with a stray domestic animal solely to his remedy in negligence.

Analysis

The court analyzed the facts of the case in light of the legal principles established in the Decker case and the Restatement. It concluded that the donkey's presence on the interstate did not constitute a wrongful act that would impose strict liability on Main. The court emphasized that strict liability applies primarily in cases of trespass by domestic animals, and since the donkey's presence did not meet the criteria for such liability, the owner could not be held responsible without a finding of negligence.

The Superior Court misinterpreted the Decker court's use of the word 'wrongfully' when it included in that term the donkey's extremely inappropriate presence on the interstate.

Conclusion

The Supreme Judicial Court vacated the judgment against Main and remanded the case with directions to enter judgment for the defendant, concluding that strict liability did not apply in this situation.

The entry is: Judgment vacated. Remanded with directions to enter judgment for defendant.

Who won?

Peter Main prevailed in the case because the court found that he was not strictly liable for the damages caused by his donkey, as its presence on the interstate was not deemed wrongful under the law.

Main urges us that the Superior Court erred in relying upon Decker v. Gammon, 44 Me. 322 (1857), as authority for imposing strict liability upon him and that there is no basis in common law for finding strict liability on the facts of this case.

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