Cothran v. Brown

ANDERSON, J.,

(concurring in result only):

I respectfully concur in result only. I vote to-AFFIRM.

This factual and legal scenario is imbued with a doleful and melancholic history. I disagree with the reasoning and analysis of the majority. The reliance by the majority on federal case law in analyzing Rule 56(c), SCRCP is unnecessary. The application of the judicial estoppel doctrine is dispositive. The case presents the paradigmatic judicial estoppel imbroglio.

I. Definition and Purpose of the Judicial Estoppel Doctrine

A court must be able to rely on the statements made by the parties because truth is the bedrock of justice. See, e.g, Douglas v. Allen, 43 Misc.2d 35, 249 N.Y.S.2d 973, 977 (N.Y.Sup.Ct.1964) (“[A] false oath smacks at the very foundation of our everyday moral code of human relations and to justice itself for without truth we could have no justice.”). Therefore, a litigant cannot “blow both hot and cold.” McDanels v. General Ins. Co. of Am., 1 Cal.App.2d 454, 36 P.2d 829, 832 (1934). Under the doctrine of judicial estoppel, a party that has assumed a particular position in a judicial proceeding, via its pleadings, statements, or contentions made under oath, is prohibited from adopting an inconsistent posture in subsequent proceedings. See 28 Am.Jur.2d Estoppel and Waiver § 74 (2000) (“The fundamental concept of judicial estoppel is that a party in a judicial proceeding is barred from denying or contradicting sworn statements made therein.”) (footnote omitted); see also City of New York v. Black Garter, 179 Misc.2d 597, 685 N.Y.S.2d 606, 607-08 (N.Y.Sup.Ct.1999) (“Judicial estoppel, or the doctrine of inconsistent positions, precludes a party who assumed a certain position in a prior legal proceeding ... from assuming a contrary position in another action simply because his or her interests have changed.... The doctrine rests upon the principle that a litigant ‘should not be permitted ... to lead a court to find a fact one way and then contend in another judicial proceeding that the same fact should be found otherwise.’ ”) (citations omitted).

*364The purpose of judicial estoppel is to prevent the manipulation of the judicial system by the litigants. Case of Canavan, 432 Mass. 304, 733 N.E.2d 1042 (2000); see also 31 C.J.S. Estoppel and Waiver § 139 (1996) (“The ... function of judicial estoppel is to protect the integrity of the judicial process ... rather than to protect litigants from allegedly improper conduct by their adversaries.”) (footnotes omitted). A court invokes judicial estoppel to prevent a party from changing its position over the course of judicial proceedings. 31 C.J.S. Estoppel and Waiver § 139 (1996). The doctrine estops a party from playing “fast-and-loose” with the courts or to trifle with the proceedings. Id. (footnotes omitted).

A quintessential case illustrating the efficacy and application of judicial estoppel is Allen v. Zurich Insurance Company, 667 F.2d 1162 (4th Cir.1982). Allen was assisting Zurich’s insured, Scruggs, in installing a mobile home when the home — which Scruggs had placed on blocks — shifted, fell, and crushed Allen’s hand. Allen sued Scruggs in South Carolina state court on a negligence theory to recover for his injuries “while in the employment of the Defendant, Carl H. Scruggs.....” Id. at 1163. Zurich defended Scruggs. The jury returned a verdict for Allen of $37,000, which Scruggs did not pay.

Allen then brought suit in federal .court against Zurich to collect on Scruggs’ automobile liability policy and alleged in the complaint he and Scruggs were joint venturers. Zurich claimed it was not liable because Allen was Scruggs’ employee at the time of his injury and the policy expressly excluded coverage for bodily injury to any employee. Allen testified he thought he was Scruggs’ employee when the accident occurred, but now characterized their relationship as “working together.” Id. During cross-examination, Allen admitted he had testified he was Scruggs’ employee and was paid a weekly salary at the time of his injury in a South Carolina Industrial Commission hearing, in a deposition, and before the state court. A verdict was returned for Allen. Zurich moved for judgment notwithstanding the verdict on two grounds: (1) Allen’s status as an employee of Scruggs was affirmatively adjudicated in state court and Allen was bound by that determination; and (2) the only reasonable inference to be drawn from the evidence presented at trial is that Allen was *365Scruggs’ employee and acting within the scope of his employment when he was injured. The district court granted the motion on the second ground. Id. at 1164.

The Fourth Circuit affirmed the JNOV order on the grounds of judicial estoppel:

Closely related to collateral estoppel, but dissimilar in critical respects, is another principle that we conclude should preclude Allen on the dispositive issue. In certain circumstances a party may properly be precluded as a matter of law from adopting a legal position in conflict with one earlier taken in the same or related litigation. “Judicial estoppel” is invoked in these circumstances to prevent the party from “playing fast and loose” with the courts, and to protect the essential integrity of the judicial process.

Id. at 1166 (citations omitted).

The court was persuaded the doctrine was applicable in Allen’s case: “Here is a party who, as the record conclusively shows, has earlier ... asserted a legal position respecting his employment relationship with another that is completely at odds with the position now asserted.” Id. at 1167 (footnote omitted).

Judicial estoppel’s essential function and justification is “to prevent the use of ‘intentional self-contradiction ... as a means of obtaining unfair advantage in a forum provided for suitors seeking justice.’ ” Id. (citation omitted).

II. History of the Application of Judicial Estoppel Doctrine by South Carolina State Courts

The South Carolina decision expressly embracing judicial estoppel is Hayne Federal Credit Union v. Bailey, 327 S.C. 242, 489 S.E.2d 472 (1997). However, several state court cases tangentially addressed judicial estoppel as a cognizable legal principle in South Carolina many years before the Hayne decision.

The Hayne Court explicitly adopted the doctrine, stating: In order for the judicial process to function properly, litigants must approach it in a truthful manner. Although parties may vigorously assert their version of the facts, they may not misrepresent those facts in order to gain advantage in the process. The doctrine thus punishes those who take *366the truth-seeking function of the system lightly. When a party has formally asserted a certain version of the facts in litigation, he cannot later change those facts when the initial version no longer suits him.

Id. at 251-52, 489 S.E.2d at 477.

While it noted some jurisdictions had expanded judicial estoppel to conclusions of law or assertions of legal theories, the Hayne Court held the doctrine’s application applied only to inconsistent statements of fact. Id. at 251, 489 S.E.2d at 477 (citation omitted).

In Boykin v. Prioleau, 255 S.C. 437, 179 S.E.2d 599 (1971), the Supreme Court touched on the doctrine as it related to the case: “The defense of judicial estoppel has not been raised, and the facts appearing here ,would not support it.” Id. at 441, 179 S.E.2d at 601 (citation omitted).

In Zimmerman v. Central Union Bank, 194 S.C. 518, 8 S.E.2d 359 (1940), the dispositive issue was whether the Circuit Court or the state’s banking board had jurisdiction over liquidation of the bank. In a prior matter, the receivers had successfully contended the banking board was empowered to govern the liquidation. In subsequent proceedings, the receivers took the opposite tack. The Court forbade the receiver’s change in position by reciting a maxim promulgated by the United States Supreme Court in Davis v. Wakelee, 156 U.S. 680, 689, 15 S.Ct. 555, 558, 39 L.Ed. 578 (1895): “[W]here a party assumes a certain position in a legal proceeding ... he may not thereafter, simply because his interests have changed, assume a contrary position.” Id. at 532, 8 S.E.2d at 365.

This Court has applied judicial estoppel in several cases since the Hayne Court expressly adopted the doctrine. See, e.g., Carrigg v. Cannon, 347 S.C. 75, 552 S.E.2d 767 (Ct.App.2001) (per curiam); Quinn v. Sharon Corporation, 343 S.C. 411, 540 S.E.2d 474 (Ct.App.2000) (majority and concurring opinions); Hawkins v. Bruno Yacht Sales, 342 S.C. 352, 536 S.E.2d 698 (Ct.App.2001), cert. granted.

III. Technical Application of the Judicial Estoppel Doctrine

Judicial estoppel is an equitable concept; therefore, its application is within the discretion of the court. 31 C.J.S. *367Estoppel and Waiver § 139 (1996). There is no fixed method or formula that courts must follow in the doctrine’s application. Id.; Allen v. Zurich Insurance Company, 667 F.2d 1162 (4th Cir.1982). Nevertheless, an analytical construct has emerged to guide our courts’ utilization of the doctrine.

The court must determine if the factual and procedural circumstances of a case at bar make application of judicial estoppel permissible. Proper application generally requires the satisfaction of the following five criteria:

(1) two inconsistent positions must be taken by the same party or parties in privity with each other;
(2) the two inconsistent positions were both made pursuant to sworn statements;
(3) the positions must be taken in the same or related proceedings involving the same parties in privity with each other;
(4) the inconsistency must be part of an intentional effort to mislead the court; and
(5) the two positions must be totally inconsistent — that is, the truth of one position must necessarily preclude the veracity of the other position.

Quinn v. The Sharon Corporation, 343 S.C. 411, 540 S.E.2d 474 (Ct.App.2000) (Anderson, J., concurring), discussed in John S. Nichols, Safeguarding the Truth in Court: The Doctrine of Judicial Estoppel, 13-FEB S.C. Law. 32 (2002).

These criteria have enjoyed the approbation of our appellate courts, as evinced by their recitation in several opinions following the Quinn concurrence. See, e.g, Carrigg, 347 S.C. at 83, 552 S.E.2d at 771-72.

The United States Supreme Court has recently addressed the issue of judicial estoppel. In New Hampshire v. Maine, 532 U.S. 742, 121 S.Ct. 1808, 149 L.Ed.2d 968 (2001), the Court presided over a boundary dispute between the two states. Specifically, New Hampshire contended its boundary with Maine ran along the Maine shore, such that the Piscataqua River and all of Portsmouth Harbor belonged to New Hampshire. The Court dismissed the suit, holding that under the doctrine of judicial estoppel, New Hampshire was equitably precluded from asserting the river’s boundary ran along *368the Maine shore because the position was in contravention to the stance New Hampshire took in litigation with Maine during the 1970’s.

In the 1970’s action, New Hampshire and Maine expressly agreed a 1740 decree fixed the boundary in the Piscataqua Harbor area. The states’ quarrel was over the location of the “Mouth of Piscataqua River,” “Middle of the River,” and “Middle of the Harbour” within the contemplation of the decree. The states drafted a settlement in which they agreed the words “Middle of the River” in the 1740 decree referred to the middle of the Piscataqua River’s main channel of navigation. The United States Supreme Court accepted the agreement and issued a final decree, which defined “Middle of the River” as “the middle of the main channel of navigation of the Piscataqua River.” Id. at 747, 121 S.Ct. at 1813 (citation omitted). Because of this previous litigation, New Hampshire was precluded from asserting a different argument concerning the boundary’s location in the later action.

In its analysis, the Court articulated three factors it found beneficent when determining whether judicial estoppel should be applied against New Hampshire’s claims:

First, a party’s later position must be “clearly inconsistent” with its earlier position.
Second, courts regularly inquire whether the party has succeeded in persuading a court to accept that party’s earlier position, so that judicial acceptance of an inconsistent position in a later proceeding would create “the perception that either the first or the second court was misled[.]” Absent success in a prior proceeding, a party’s later inconsistent position introduces no “risk of inconsistent court determinations,” and thus poses little threat to judicial integrity.
A third consideration is whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.

Id. at 750, 121 S.Ct. at 1815 (citations omitted).

The New Hampshire Court’s factor concerning a litigant’s prior success in persuading a tribunal to accept the litigant’s *369earlier position differs from the policy articulated within the Quinn concurrence. Quinn was influenced in large part upon the rule enunciated within the seminal case involving the judicial estoppel doctrine, Hamilton v. Zimmerman, 37 Tenn. (5 Sneed) 39 (Tenn.1857). Under the Hamilton rule, anytime a party asserts a position under oath, that party is precluded from repudiating that position in a later proceeding. Hamilton, 37 Tenn. (5 Sneed) at 47-48, analyzed in Rand G. Boyers, Precluding Inconsistent Statements: The Doctrine of Judicial Estoppel, 80 Nw. U.L.Rev. 1244 (1986).

With the enumeration of the five factors in the Quinn concurrence and Carrigg, South Carolina clearly did not adopt the Hamilton rule in a wholesale manner. Limitations on the application of judicial estoppel do exist. Nevertheless, the Quinn concurrence demonstrates there is sanctity in the oath and whether the litigant enjoyed prior success with an earlier averment is immaterial:

As originally conceived in Hamilton v. Zimmerman, the doctrine of judicial estoppel was based solely on the sanctity of the oath. Under this philosophy, the fact a litigant is using the court as a forum for his inconsistent statements injures the judicial system; therefore, such abuse must be avoided under all circumstances. Any perpetuation of untruth or misrepresentation eviscerates public confidence in the integrity of the judicial system. Accordingly, whether a party was successful or not in propounding the validity of its initial position is immaterial: the party will be judicially estopped from assuming a different stance, relating to the facts, in subsequent proceedings.

Id. at 422, 540 S.E.2d at 480 (emphasis added) (citations omitted).

In contrariety, the majority of jurisdictions that recognize the doctrine of judicial estoppel follow the “judicial integrity” policy. Boyers, supra, at 1252. This policy provides the rationale for the “prior success” condition. Id. at 1253. The policy is grounded in the following logic: If there was no previous judicial acceptance of the contrary position, then no risk of inconsistent results exists. If there is no risk of inconsistent results, then the integrity of the judicial process is not threatened. If the integrity of the judicial process is *370not threatened, then there is no policy justification warranting application of judicial estoppel. Id.

Support for application of the judicial estoppel doctrine without a showing of prior success can be found in Allen v. Zurich Insurance Company, 667 F.2d 1162 (4th Cir.1982), a federal appellate court case emanating from South Carolina. In Allen, the Fourth Circuit stated application of the judicial estoppel doctrine is “perhaps not necessarily confined to situations where the party asserting the earlier contrary position there prevailed....” Id. at 1167.

Additionally, our Supreme Court has arguably indicated prior success is not a criterion with its condition-less pronouncement regarding application of the doctrine in Hayne Federal Credit Union v. Bailey, 327 S.C. 242, 489 S.E.2d 472 (1997): “When a party has formally asserted a certain version of the facts in litigation, he cannot later change those facts when the initial version no longer suits him.” Id. at 252, 489 S.E.2d at 477.

Moreover, the New Hampshire Court itself gives tribunals the discretion to examine whatever factors they desire when considering application of judicial estoppel:

In enumerating these factors, we do not establish indexible prerequisites or an exhaustive formula for determining the applicability of judicial estoppel. Additional considerations may inform the doctrine’s application in specific factual contexts.

Id. at 752, 121 S.Ct. at 1815 (emphasis added).

A conclusive determination of the course South Carolina’s state courts should follow concerning the prior success element is unnecessary for purposes of adjudicating the instant case. The appellant, Alvin Brown, averred at the guilty plea hearing that he was solely responsible for the accident. This asseveration was clearly a tactic Brown used to obtain a lesser sentence from the plea judge. A defendant’s admission of guilt is a proper consideration for a plea judge when considering the defendant’s sentence. See State v. Brouwer, 346 S.C. 375, 391, 550 S.E.2d 915, 924 (Ct.App.2001) (Anderson, J., dissenting) (“A genuine admission of guilt may properly result in a lighter sentence than would be appropriate for an intransigent and unrepentant malefactor.”) (citation omitted). *371Brown’s admission at the plea hearing was arguably successful, especially in light of the egregiousness of his crime. Instead of receiving the ten-year maximum prescribed by statute, the plea judge sentenced Brown to a six-year term.

IV. Application of the Judicial Estoppel Doctrine in the Case Sub Judice

Respondent Ferrell Cothran, as personal representative of the Estate of Douglas H. McFaddin, contends this Court erred in its initial opinion by concluding Brown has not yet had a full and fair opportunity to dispute whether McFaddin contributed to the accident. To the contrary, the record clearly reveals the relative degree of culpability and Brown’s lata cupla were at issue and decided at the guilty plea hearing. Brown is bound by the factual admissions and statements he made during those proceedings, which definitively show Brown was completely responsible for causing the accident. Accordingly, I find Brown has had a full and fair opportunity to contest the issue of McFaddin’s relative fault.

Indubitably, Brown made the relative fault of the parties an issue in his guilty plea. He did so by specifically representing to the plea judge the accident was a result of his drinking and that no “blame whatsoever should be placed on Mr. McFaddin,” who Brown declared did not have “anything to do with the accident.” Brown intentionally put this issue before the plea judge with the goal of obtaining a lesser sentence. Brown did obtain a lesser sentence — instead of receiving the ten-year maximum sentence authorized by statute for reckless homicide, he was sentenced to a six-year term of imprisonment.

Considering the fact the relative fault of the parties was at issue during the guilty plea and Brown specifically represented McFaddin was not to blame for the accident whatsoever, and further considering Brown obtained the benefit of a reduced sentence after having accepted responsibility for the accident, I conclude the Circuit Court was correct in holding Brown was judicially estopped from contesting liability in the civil suit. The circuit judge properly granted summary judgment to Cothran on the issue of liability.