M. Pierre Equipment Company, Inc. v. Griffith Consumers Company

831 A.2d 1036 (D.C. 2003) · District of Columbia Court of Appeals · September 18, 2003 · No. 01-CV-1476, 02-CV-303 and 02-CV-304

Summary

The District of Columbia Court of Appeals affirmed a judgment awarding a settling tortfeasor pro rata contribution from a non-settling tortfeasor arising from a basement oil spill. The court held that a settling tortfeasor seeking contribution must establish the non-settling tortfeasor’s common liability and the reasonableness of the settlement. The court also upheld the trial court’s evidentiary rulings and denial of judgment as a matter of law and prejudgment interest.

Holdings

  1. A settling tortfeasor bringing a contribution action against a non-settling tortfeasor in the District of Columbia has the burden of establishing the non-settling tortfeasor's liability to the injured person and the reasonableness of the settlement.
  2. The trial court did not abuse its discretion in making evidentiary decisions concerning the damages relevant to the reasonableness of Griffith's settlement.
  3. The trial court properly denied Pierre's motions for judgment as a matter of law because substantial evidence supported findings that Pierre was negligent, its negligence proximately caused the oil spill, and the Galstons were not contributorily negligent.
  4. Griffith was not entitled to prejudgment interest because the amount owed was not a liquidated debt or an easily ascertainable sum certain before the jury rendered its $600,000 verdict.

Questions Presented

  1. In a contribution action by a settling tortfeasor against a non-settling tortfeasor, must the settling tortfeasor prove the non-settling tortfeasor's common liability and the reasonableness of the settlement?
  2. Did the trial court properly exercise its discretion in admitting and excluding evidence concerning the damages and reasonableness of the settlement?
  3. Was Pierre entitled to judgment as a matter of law on the evidence of negligence, proximate cause, and contributory negligence?
  4. Was Griffith entitled to prejudgment interest on the settlement amount under D.C. Code § 15-108?

Disposition

affirmed

Cases Cited (17)

  • Hubbard v. Chidel, 790 A.2d 558, 567 (D.C. 2002)(followed)
  • Jones v. Schramm, 141 U.S. App. D.C. 169, 172-73 n.11, 436 F.2d 899, 902 (1970)(followed)
  • District of Columbia v. Washington Hosp. Ctr., 722 A.2d 332, 336 (D.C. 1998) (en banc)(followed)
  • Martello v. Hawley, 112 U.S. App. D.C. 129, 131, 300 F.2d 721, 723 (1962)(followed)
  • Automobile Underwriters Corp. v. Harrelson, 409 N.W.2d 688, 690 (Iowa 1987)(followed)
  • Transport Ins. Co. v. Chrysler Corp., 71 F.3d 720, 722 (8th Cir. 1995)(followed)
  • Traveler's Ins. Co. v. United States, 283 F. Supp. 14, 31 (S.D. Tex. 1968)(followed)
  • Square 345 Assocs. Ltd. P'ship v. District of Columbia, 721 A.2d 963, 969 (D.C. 1998)(followed)
  • Roundtree v. United States, 581 A.2d 315, 328 (D.C. 1990)(followed)
  • City of Tucson v. Superior Court, 165 Ariz. 236, 798 P.2d 374, 380 (1990)(followed)

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