Byram v. Main
Maine Supreme Judicial Court
523 A.2d 1387 (1987)
- Written by Craig Conway, LLM
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. Byram then amended his complaint to add a strict-liability count, and the original negligence count was dismissed by stipulation of the parties. After a second jury-waived trial, the court found Main strictly liable for the damage caused to Byram’s rig and awarded Byram 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
Issue
Holding and Reasoning (McKusick, C.J.)
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