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Albert Bros. Construction, Inc. v. Gagnon
Citations: 611 A.2d 75; 1992 Me. LEXIS 183
Court: Supreme Judicial Court of Maine; July 20, 1992; Maine; State Supreme Court
Defendants Raynold and Rina Gagnon contracted with plaintiff Albert Brothers Construction, Inc. (Albert Bros.) for house construction. After completion, Albert Bros. sued the Gagnons in the District Court (Madawaska) for $6,705.70, the balance owed for their work. The Gagnons counterclaimed for $10,000, asserting the house was not built in a good and workmanlike manner. The District Court, presided by Judge Daigle, ruled in favor of Albert Bros., awarding them $5,942.10 after deducting $3,888.36 from the Gagnons' counterclaim. The court subsequently allowed the Gagnons to recover their costs while denying those of Albert Bros. This cost award was affirmed by the Superior Court (Aroostook County, Judge Pierson), prompting an appeal from Albert Bros. The court's decision to award costs to the Gagnons was based on the determination that they were the prevailing party, applying a "functional analysis" from prior case law (Dodge v. United Serv. Auto. Ass’n). However, the analysis in this case was deemed flawed, as Albert Bros. achieved a net judgment in their favor of slightly over $2,000, which was a significant outcome compared to the Gagnons' pre-lawsuit offers and claims. The appellate court held that Albert Bros. clearly prevailed in the trial, necessitating a vacating of the cost award. The judgment was vacated, and the case was remanded to the Superior Court with instructions to send it back to the District Court for further proceedings in line with this opinion. All justices concurred in this decision.