Coachmen Industries, Inc. v. Crown Steel Co.

Citations: 577 N.E.2d 602; 1991 Ind. App. LEXIS 1405; 1991 WL 166245Docket: No. 20A03-9104-CV-106

Court: Indiana Court of Appeals; August 29, 1991; Indiana; State Appellate Court

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Coachmen Industries, Inc. (Coachmen) appeals a judgment against it following a bench trial initiated by Crown Steel Co. (Crown) for the value of steel delivered to Coachmen's Auranco division, which Coachmen rejected as defective. Crown arranged to resell the steel, with Coachmen agreeing to hold it, but the steel was missing when a buyer's trucking company arrived for pickup. The trial court ruled that Coachmen, as a gratuitous bailee, breached its duty of "slight care" over the steel. Coachmen raises three issues for review, consolidated into whether the trial court's judgment is clearly erroneous. Crown contends the judgment should be affirmed due to Coachmen's procedural noncompliance, but the court decides to address the appeal's merits, finding the violations insufficient for dismissal or summary affirmance. The trial court provided specific findings of fact and conclusions of law, and the appellate review standard requires verifying that evidence supports these findings and that the findings support the judgment. The court will not reweigh evidence or reassess witness credibility unless a clear error is found. The parties agree that Coachmen held the steel solely for Crown’s benefit, imposing a duty of slight care on Coachmen, which is only liable for gross neglect. Gross negligence is characterized as a severe failure to uphold legal duty, distinct from a mere lack of ordinary care.

Indifference to legal duties and a lack of adequate care in handling obligations can lead to liability, as noted in Black's Law Dictionary. In the amended judgment, the trial court established several facts: Auranco Enterprises is a division of Coachmen; Auranco and Crown had a contract for 51,800 pounds of steel; on May 27, 1988, Tompkins Trucking delivered the steel to Auranco; employees Mason and Desimone inspected and rejected the steel, officially notifying Crown of this rejection the same day; Desimone agreed to hold the steel for Crown; Mason unloaded the steel; Crown subsequently resold the steel but could not locate it at Auranco’s facility when it requested pickup; neither Coachmen nor Auranco returned the steel or compensated Crown for it. 

The court noted Auranco's prior pattern of rejecting and later accepting steel shipments. Coachmen contested the findings, claiming a lack of specific determination regarding its duty of care in the bailment; however, it acknowledged the trial court's conclusion that Auranco, as a gratuitous bailee, failed to exercise the required slight care. The trial court's conclusions explicitly stated that Auranco breached its duty of care, and this breach was clearly articulated within the judgment, countering Coachmen's argument that the existence of breach could not be inferred. The court emphasized adherence to trial rules aimed at ensuring just and efficient resolution of cases.

TR 52 eliminates the old distinctions regarding the classification of findings as evidentiary facts, ultimate facts, conclusions of fact, or conclusions of law. Trial court findings should be interpreted liberally to support the judgment, as long as they are backed by evidence of probative value. The judgment favoring Crown is upheld based on sufficient findings. Coachmen's claim that the finding of a breach of slight care lacks evidentiary support is rejected. Evidence indicates that Coachmen acknowledged receipt of 51,300 pounds of steel, which was not returned or paid for. Despite witnesses testifying ignorance of any danger to the steel, the court finds that Coachmen's inability to account for the steel demonstrates a failure to exercise slight care, and the request to reweigh evidence is not permissible under the standard of review. Coachmen's argument that the trial court found it liable for ordinary negligence is also dismissed; the court concluded that Coachmen did not meet the slight care standard required of a gratuitous bailee. The judgment is affirmed, with specific procedural recommendations for future appellate filings. The only change in the amended judgment was the removal of the word "reasonable" from a description of Auranco's care.