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Byram v. Main

Maine Supreme Judicial Court
523 A.2d 1387 (1987)


Facts

Ray Byram (plaintiff) filed a negligence suit against Peter Main (defendant) after a pet donkey belonging to Main’s daughter escaped from an enclosure, wandered onto a public interstate highway, and was struck by a tractor-trailer rig driven by Byram. After a trial, the trial court directed a verdict for Main on Byram’s negligence claim. Byram appealed. The Maine Supreme Judicial Court reversed and remanded the matter to the trial court. Thereafter, Byram amended his complaint to add a strict liability count and by stipulation of the parties, the original negligence count was dismissed. After a second, jury-waived trial the court found Main strictly liable for the damage caused to Byram’s rig and awarded him over $27,000 in damages. Main appealed, arguing that the trial court erred in relying upon Decker v. Gammon, 44 Me. 322 (1857), as authority for imposing strict liability based on the facts of the case. The Maine Supreme Judicial Court granted certiorari to review.

Rule of Law

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Issue

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Holding and Reasoning (McKusick, C.J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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