Sterling Mirror of Maryland, Inc. v. Gordon

FERREN, Associate Judge,

dissenting:

In my judgment, this appeal should fail for want of an adequate record on appeal. *70In Cobb v. Standard Drug Co., Inc., 453 A.2d 110 (D.C.1982), we said:

A judgment of any trial court is presumed to be valid. A losing party who notes an appeal from such a judgment bears the burden of “convincing the appellate court that the trial court erred.” In meeting that burden, it is appellant’s duty to present this court with a record sufficient to show affirmatively that error occurred. The responsibility of perfecting the record remains with appellant and “cannot be shifted to either the trial court or this court.”

Id. at 111 (citations omitted, emphasis added). Sterling Mirror did not meet the Cobb standard requiring appellant to provide a record that assuredly reflects at least a prima facie basis for reversal, because Sterling Mirror did not even provide the pleadings or a transcript that unquestionably showed the nature and scope of the counterclaim under attack on appeal. The majority’s speculation about the counterclaim impermissibly attempts to compensate for these imperfections in the record supplied by appellant.

I.

An appellee has no burden to produce any part of the record on appeal unless appellant has supplied a record showing a prima facie basis for reversal, as our case-law development shows. The earliest decision cited by the majority, Dulles v. Dulles, 302 A.2d 59, 60 (D.C.1973), as well as similar cases coming before and after it, do not apply to this case because they concern the efforts of both parties to provide a statement of proceedings and evidence, in lieu of transcript, pursuant to D.C.App.R. 10(j) (currently D.C.App.R. 10(d)). See Cole v. United States, 478 A.2d 277, 283-85 (D.C.1984); Voight & McMakin Air Conditioning, Inc. v. Property Redevelopment Corp., 276 A.2d 239, 241 n. 2 (D.C.1971). In a missing transcript situation, the trial court has the ultimate responsibility for constructing an adequate record for review, see Cole, 478 A.2d at 284; Dulles, 302 A.2d at 60, and thus, quite naturally, a court rule requires both parties to lend a hand.1

The first of our decisions bearing on this case is Parker v. Stein, 557 A.2d 1319 (D.C.1989). There, we reversed the denial of a motion for a new trial on punitive damages and emotional distress. Both claims were well pleaded and supported by the transcript included in the record. The only question of the record’s adequacy arose with respect to whether there may have been trial judge rulings, omitted from the record on appeal, that would have helped the defendant-appellee if he had supplied them to this court. In Parker, therefore, appellant had provided a record adequate to sustain his appeal, in effect shifting the burden of production to appel-lee to show otherwise — a burden he failed to meet.2 In contrast, as elaborated in Part II below, Sterling Mirror failed to provide a record plainly reflecting a prima facie basis for reversal.

Since deciding Parker in 1989, this court has applied it twice in circumstances similar to those in this case. The first decision, Smith v. Jenkins, 562 A.2d 610 (D.C.1989), concerned — as in this case — a “record [that] does not include a copy of the [relevant] counterclaim.” Id. at 612 n. 2. In affirming, we reiterated Cobb’s rule “that the party seeking reversal bears the burden of presenting a record sufficient to show that error occurred, and if the record is insufficient for that purpose, we lack discretion to reverse.” Id. (citations omitted). Two years later in Sparrow World Baptist Church v. E.M. Willis & Sons, 594 A.2d 549 (D.C.1991), we reversed and remanded because “nothing in the record on appeal supports appellee’s claim,” citing Parker for the proposition that “appellee *71must provide a record on appeal to support its contentions once appellant has presented a record to support appellant’s contentions on appeal,” id. at 552 (emphasis added), as appellant had in Parker.

Our caselaw, therefore — from Cobb through Sparrow World Baptist Church — makes clear that appellee has no burden to produce any part of the record on appeal unless appellant has supplied a record showing a prima facie basis for reversal. Here appellant, Sterling Mirror, has not met this initial burden.

II.

In the case under review, Sterling Mirror did not supply this court either with a copy of its complaint or with a copy of Mrs. Gordon’s counterclaim.3 Without the counterclaim before us, it is impossible — aside from speculation — to decide whether the trial court improperly awarded damages on that counterclaim.

The trial court did not specify the legal theory behind its ruling on Mrs. Gordon’s counterclaim:

And as to the claim, counterclaim of Mrs. Gordon, I find that there again on that claim, her testimony is unrebutted and unaddressed by the defendant — by the plaintiff, not the defendant, and that there were a large number of calls to her job with respect to a contract that she didn’t sign and had not participated in in any way.
* * * * * *
[T]he counter-claimant. Daisy Gordon [shall] recover of the counter-defendant Sterling Mirror of Maryland the sum of $1,000.00 with interest at the rate of 8% as provided by law, and her costs of action.

(Emphasis added). By presenting no evidence at trial in response to Mrs. Gordon’s counterclaim, Sterling Mirror apparently assumed that the court would find that Mrs. Gordon had not affirmatively proved all the elements of her cause of action. Now, having lost at trial on the basis of that assumption, Sterling Mirror still wants to contend that she has not proved her case without supplying this court with the counterclaim necessary to identify her legal theory or theories and the essential elements of her cause or causes of action.

Moreover, Sterling Mirror has not even supplied a complete transcript of the proceedings; we have only Mrs. Gordon’s testimony. Even though the court reporter’s transcription of this testimony appears to be complete, I would fault Sterling Mirror — under the circumstances — for ordering only Mrs. Gordon’s testimony. Between Mrs. Gordon’s testimony and the trial court’s findings the court reporter inserted the following entry:

[There followed further testimony and colloquy, which proceedings were reported but are not requested to be transcribed herein, and the proceedings continued further, as follows:]

This “further testimony” by some unidentified witness or witnesses for Mrs. Gordon4 may have provided additional proof for some element of her legal theory, whatever it was. I will assume the majority’s doubtful proposition — solely for the sake of argument — that this court can comb the trial record, even without access to an appellee’s pleadings, to discern whether that party did, or did not, prove some kind of claim. But surely, in that case, this court must *72have access to the entire transcript in order to evaluate any possible cause of action. Otherwise, the court will have no justification for agreeing (as Sterling Mirror would have us say here) that “[n]o common law basis for [the trial court’s] decision can be found.”

Nonetheless, without the benefit of pleadings or of a complete transcript, the majority speculates as to what Mrs. Gordon’s counterclaim is all about, proffering two statutes and a common law theory, and then shoots each down.5 The trial court, however, in its findings and judgment, did not cite either statute or any common law theory. It is not for this court to say that missing pleadings and an incomplete transcript could not have justified recovery. My colleagues in the majority — acting first as Mrs. Gordon’s lawyer to identify her theories, and then as appellate judges to reject them — may well be right that they have identified the only possible theories of recovery for a counterclaim,6 and that the record, if completely revealed to us, would not support liability under any of them. But the majority may be wrong, and its approach sets a very bad precedent.

Think of the implications. There can be a multi-count complaint and counterclaim in a complex field of commercial law where certain, very specific allegations are required for each. If a losing party, in taking an appeal, does not provide us with the pleadings and all relevant portions of the transcript, I do not see how we, as judges, can properly conclude that the prevailing party and the trial judge or other trier of fact were wrong. If an appellant, in a brief, purports to state the facts and then throws out legal arguments that may or may not be dispositive, but cannot be tested against a formal complaint and a complete record, this court cannot responsibly decide the case.

I believe we have only one choice here: to affirm the judgment for lack of an adequate record on appeal to justify any other disposition.

. In remanding for further proceedings in Dulles, we faulted the trial court for certifying the inadequate record presented; we did not ascribe that failure to appellee.

. Like the majority opinion in the present case, Parker cites Dulles outside the context of D.C.App.R. 10(j) (now D.C.App.R. 10(d)), but only for the proposition that responsibility for producing record support for an argument on appeal shifts to appellee after appellant has met the burden imposed by Cobb. See Parker, 557 A.2d at 1323.

. Sterling Mirror filed a brief but Mrs. Gordon did not. The case was assigned to our summary calendar, and neither party asked for oral argument.

. By ordering only Mrs. Gordon's testimony. Sterling Mirror implies that it is the only portion of the proceedings relevant to her counterclaim, but Sterling Mirror provides no proof— other than Mrs. Gordon’s failure to demand additional portions of the transcript — on which this court can base such a conclusion. While an entry in the official record of the proceedings states "Defendant’s testimony completed,” perhaps suggesting that only one witness appeared, we know that both Mr. and Mrs. Gordon were defendants and that both testified. Although the trial judge mentioned only Mrs. Gordon’s testimony in evaluating her counterclaim, the court reporter's notation about "further testimony" raised questions about additional evidence that Sterling Mirror — not this court — has the responsibility to resolve.

. After noting in its brief that the trial court "did not state the basis of the decision” and merely asserting that "[n]o common law basis for such a decision can be found,” Sterling Mirror concludes that the court must have "erroneously based its decision upon either the Federal or the District of Columbia statutes regulating debt collection, neither of which are applicable to this case.”

. Based on the portion of the transcript filed by Sterling Mirror, Mrs. Gordon testified, in part:

And before I — before I got to work, came back to work because I had been out for a few weeks, my supervisor had been telling me that someone had been calling me and something had to be done about it because she couldn’t put up with it any longer because they were constantly calling and asking to speak to me. They were from Sterling Mirrors.
So, once I came back to work then, you know, I started getting these calls from a man, and he was telling me the same thing. He said you’ll have to pay this money, and I said money, for what? Aatd he said you and your husband had purchased some mirrors. I told him, I said, I haven’t purchased any mirrors.
******
The only thing I want to say the harassment that I went through really caused me a lot of hardship on my job, because I work in the same — I work for the same people, but I was moved, and I think the reason why I was moved is because they got tired of the harassment. And my supervisor told me even after I was moved that the calls continued to come in from Sterling Mirrors, different people calling constantly about this money, and so, I just, you know, I just told her like this. I am gone. There is nothing I can do. But on my husband’s behalf, he is a very sick man. He is 100 percent disabled veteran. He doesn’t have any problems with paying his bills because we have a pretty nice home and stuff like that, and I think that is really rotten that I would have to lose time off my job and possibly be in a situation where I have to deal with him getting sicker because of this, because it is hard pushing a wheelchair when you don’t have to for some stuff, and you losing your leave and all this kind of stuff.