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Question

when a plaintiff makes an argument that the cost of correcting stairs by rebuilding is not less than $7K and as such they have suffered damages in an amount certain of not less than $7K are there any special arguments that can be made if it is proven that they 1) did not pay nor correct such work 2) that the cost to correct such work is $50 3) that the work only needs completing/upgrading vs. their claim of rebuilding, is there some special argument to make so that even if $50 is found against the defendant that they can win and not owe thousands in attorney fees?

Submitted: 25 days ago.
Category: Legal
Value: $18
Status: CLOSED
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State/Country relating to Question: Washington

Posted by Curtis Staropoli, Esq 25 days ago.

Info Request

Can you please provide some contect and detail as to how this question(s) have come to be on your ask list?

 

I am sure that I cannot give you a useful answer until I understand the context in which you are asking the question.

 

Thanks

25 days ago.

Reply

we are being sued for a full rebuild of stairs, when the plaintiffs were told by building inspectors and us prior that all that was needed was more hardware. The plaintiffs have not been injured, the stairs have not come apart or failed, the plaintiffs have failed to uphold contractual obligations for proper completion of the stairs, however, I am curious because they made their claim of damages for a rebuild (which they never made claim to prior to filing the complaint) to be certain amount not less than $7K, is there some argument that can be made that they aren't entitled to an award because they didn't argue for nominal damages or something?

Their own evidence shows that the stairs only need minimal amounts of money in upgrades $50 -$200, but they did not show any evidence that upgrades were needed at all until just before arbitration and thousands in attorney fees later. This case isn't so much about the damages as it is about the attorney costs. We have a pretty good case for a full win, but need an argument in case we could be found responsible for nominal damages.

Posted by Curtis Staropoli, Esq 25 days ago.

Answer

Ok, thanks...

 

You and plaintiff had a contract that encompasses and presumably governs the issue as to their claims for damages over the stairs -- is that correct?

 

If so, can you explain the nature of the agreement? Was there a contractual arbitration already and now you are in a post-arb period where the plaintiff has rejected the arb verdict and decided to sue in court as the contract must allow?

 

If not, please explaint your relationship to plaintiff as it pertains to the stairs....

 

In the end, if your relationship as it pertains to the stairs is contractual, then your duties and the scope thereof (or, your lack of duties) are going to be determined by the court's interpretation of the contract. if there is some other relationship as it pertains to the stairs, such as a landlord tentant relationship, different standards will apply as to duties.

 

Ultimately though, property damages are damages, and if they cannot show that they have been damaged in the amount of 7K that they have incurred or expended, or, that they are contractually entitled to 7k from you -- they will not get 7k, or, anything else.

 

You do not get "nominal" damages in a a property damage case -- wither you have a casualty or contractual property damage claim and can prove it, or, you do not.

 

I hope that this was helpful to you. If it was please remember to click "ACCEPT" on your screen to make sure that I am paid for my efforts. By clicking ACCEPT you are not giving up your right to ask more questions on this issue, and I will be happy to respond to these as well

24 days and 23 hours ago.

Reply

That sort of answers my question. THe amount puts us in mandatory arbitration. The contract was for a remodel including stairs, we had the stair framing inspected, the homeowner was contractually obligated to have all inspections performed however, and had pulled the permit himself and did not complete his electrical so that he could attempt to final the stair building permit and let the permit and our one year warranty expire. He contacted us seeking free work and bullied us to do it saying that although he chose the wood and failed to place a finish coat on the stairs as prescribed that the way the wood was warping in one are was our responsibility and he called in a code violation to the building department to bully us further. the connections had been obscurred after we passed the framing inspection, per the homeonwer's request and the permit was expired and the homeowner had left a section of stairs without a guardrail where he was supposed to have placed kitchen cabinetry, so the inspector failed the inspection. The homeowner ignored his and our indications that hardware could be added and sued us for a full rebuild without any professional assessments.

Basically I want to know that legally, if the arbitrator finds that with the way they worded their claim that if 1)the stairs do not need rebuilding or 2) that the damages (not including attorney's fees) are significantly less than the $7K, is there some precedent we can argue to ensure that we don't get stuck with their $15K in attorney's fees for their failure to mitigate or amend their claim as requested?

Posted by Curtis Staropoli, Esq 24 days and 23 hours ago.

Answer

Sure, absent a valid contractual agreement to the contrary, or a fee-shifting statute (not an issue here), or serious abuse of process, the general rule in the US is that each side bears its own attorneys fees and costs in civil litigation.

 

Your abitrator knows this rule darn well, and, knows that although everyone asks for their attorneys in theor complaints, no one gets them absent the circumstances above.

 

Indeed, absent a contract that clearly and validly says "loser pays the others fees", you should not be ordered to pay their attorney fees even if they prove their damages ARE 7K for the stairs.

 

 

I hope that this was helpful to you. If it was please remember to click "ACCEPT" on your screen to make sure that I am paid for my efforts. By clicking ACCEPT you are not giving up your right to ask more questions on this issue, and I will be happy to respond to these as well

24 days and 23 hours ago.

Reply

there is a law/statute that the prevailing party in this case is entitled to attorney's fees.

RCW 18.27.040 because they made a claim against our surety bond.

Posted by Curtis Staropoli, Esq 24 days and 23 hours ago.

Answer

Is it clear that the statute applies?

 

If so, then, the next line of defense if they "succeed" and claim the fees is of course to argue that they did not meet the statutory criteria for award of fees, the fee claims are excessive, etc.

 

I have been involved in attorney fee litigation which has become a case within a case more than once. Generally, pigs get slaughtered, so even if they win and convince the court that they meet the criteria for fee award -- 15K on a 7K damage claim is an easy target for you to knock down.

 

I hope that this was helpful to you. If it was please remember to click "ACCEPT" on your screen to make sure that I am paid for my efforts. By clicking ACCEPT you are not giving up your right to ask more questions on this issue, and I will be happy to respond to these as well

24 days and 23 hours ago.

Reply

so in cases where the claim is made "in an amount not certain than" but the nature of the complaint is entirely different, and the amount in question is proven nominal, there is no precedent that defendant should prevail?

were you saying earlier that if the arbitrator finds they aren't entitled to the full (or anywhere near)$7K it is possible that it would be found they aren't entitled to anything? Without my having to make an argument to that effect?

I am not trying to forsee possible outcomes, I am trying to get legal advice as to arguments to make, understand?

Accepted Answer

Ok, your question merges two separate issues, liability and damages.

 

First, no, it is not a default position for a defendant to simply succeed with a defense verdict where a plaintiff "claims" X dollars in damages in their complaint and/or attempts to offer proof of the same X dollars at trial and fails to prove X, but, does prove a lesser amount Y. If your plaintiff tries and fails to prove that you are liable for 7K, but does prove you are liable for 3k, then so you are. If your plaintiff proves that it sustained 700K, or $50, or 7K in damages but cannot prove that your are liable to it, then you are not liable for anything.

 

So, you need to make 2 separate attacks on their proof: (1) I am not legally liable to plaintiff, period AND (2) even if the court finds me legally liable, I am only liable in this ________ amount, not the amount claimed.

 

These attacks are made routinely at the same time at trial. So, first, they must try to prove you are at fault and you should poke holes in their proof as much as you can, and, second, they must also try to prove their damages, upon which you do the same thing. Then, when it's your case, if you have contrary evidence on liability or damages or both,

you put it in the record just as plaintiff did during their case. And, finally, when everyone has concluded their proof, you argue the evidence to the court and insist that it favors you on liability, but, also argue that -- even if the court disagrees on liability -- the damages are only _ low amount.

 

If you make sure to distinguish these concepts you will have a correct orientation to defend a case. Plaintiff has the burden of proof on liability and damages, so you need to attack their case on both fronts to try and get the best result.

 

I hope that this was helpful to you. If it was please remember to click "ACCEPT" on your screen to make sure that I am paid for my efforts. By clicking ACCEPT you are not giving up your right to ask more questions on this issue, and I will be happy to respond to these as well

 

 

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Expert: Curtis Staropoli, Esq
Pos. Feedback: 100.0 %
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Answered: 10/28/2009

Attorney

Practicing attorney for 17 years and principal of law firm.

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