Miller v. Lankow

KLAPHAKE, Judge

(dissenting).

Minnesota requires that “spoliation notice must reasonably notify the recipient of a breach or a claim.” Hoffman, 587 N.W.2d at 70. In the context of construction litigation, such notice affords the potential adverse party the opportunity to correct any defect, prepare for negotiation and litigation, and safeguard against stale claims. Id. Here, appellant provided respondents with the notice required by Hoffman, but the majority insists that in addition to providing notice of a potential claim, appellant was also required to “inform respondents of appellant’s plan to remediate the moisture and mold problems.” This additional requirement adds an additional component to the claim notice required by Hoffman and is wholly unsupported in the law. In addition, respondents have not shown that they were prejudiced by appellant’s remediation actions. Therefore, the district court’s exclusion of appellant’s evidence as a spoliation sanction was an abuse of discretion, and I would reverse.

*742The chronology of events shows that respondents were properly notified of appellant’s potential claim between September 2005, when appellant discovered the ongoing water and mold problem, and early 2007, when appellant began removing the water- and mold-damaged walls of his home. In October 2005, a potential buyer of appellant’s home opted out of the purchase after receiving a moisture analysis report obtained at the buyer’s request. When appellant received the report and apparently sought another moisture analysis that also revealed the presence of mold and water infiltration in his home, appellant and a friend who owned a residential construction business cut a hole in the drywall under a window on the inside wall of appellant’s home. They discovered in the area, which had been previously repaired, “moisture actually coming down the inside part of the wall” and “frost on the chipboard.”

According to appellant, he then telephoned the contractors who had done the previous repair work, respondents Donnelly Brothers and Total Service Company, informed them of the problem, and told them that it would have to be fixed immediately. Mark Donnelly and Jeff Agness of Total Service Company visited appellant’s home for a 45-minute meeting, where, according to appellant, they were shown the hole that had been cut in the wall, and “they both agreed that there was moisture in the wall again.” During that meeting, the contractors stated that they had repaired only limited areas of the home as per the direction of the prior homeowners, and when asked “what they could do for” appellant, Mark Donnelly offered him a “fairly good price” to repair the problem, and Jeff Agness said nothing. Agness stated in his deposition that he, Mark Donnelly, and the prior homeowners met soon after the meeting with appellant, and “[t]he purpose of the meeting was to make us aware that there may be a lawsuit on this, and for the people that were involved in that to ... take a look at what does that mean, why are we being sued, what are the issues here.”

On December 27, 2005, appellant’s counsel sent each of the contractors a letter to provide them with “written notification of potential construction defects” in the home. The letter included a copy of the moisture analysis report, which revealed the continuing mold and water infiltration problem, and discussed the discovery of “work which was done inappropriately by your companies causing the problems to continue.” The letter concluded by stating:

It is my hope that between your companies, the previous owner, and my client, we will be able to resolve this issue amicably and without much legal cost. As such, please contact me at your convenience if you wish to inspect the property and discuss possible resolutions. However, if I do not hear from you by January 9, 2006,1 will presume that you do not wish to work on a resolution and I will put the matter into suit. Thank you and look forward to speaking with you.

Appellant also sent a very similar notice letter to the former homeowners.

Thereafter, only Mark Donnelly visited the home, and, according to his affidavit, his total investigation consisted of viewing “a cut [made] on the inside wall prior to my visit.” Despite appellant’s allegation that moisture was “actually coming down the inside part of the wall” that Donnelly had repaired earlier, Donnelly did nothing after twice visiting the house to investigate the problem, did not inquire further about the extent of the damage or condition of the house, did not have an expert evaluate the problem, and did nothing to otherwise *743protect himself in the event of an adverse claim. Donnelly admits in his affidavit that appellant showed him the cut in the interior wall during his visit, but his affidavit omits to mention what Donnelly saw from viewing the cut or any conclusions he reached from this “investigation.”

In Hoffman, we said that notice was inadequate for purposes of spoliation analysis when a new car owner whose vehicle had burned in his garage did not give the ear dealership proper notice of a possible breach or claim and merely contacted the dealership by telephone to tell them that his vehicle had started on fire, to cancel a service appointment, and to request paperwork on the car. Id. at 70-71. Here, by contrast, appellant made several contacts with respondents over the course of a year and several months, and during this period he pinpointed respondents’ actions as the source of the problem, encouraged them to inspect the problem, and eventually threatened suit when they took no action. Jeff Agness’s admission that he and respondents met soon after the first meeting with appellant to discuss their legal exposure clearly shows that they were notified of a potential claim by appellant.

The fact that appellant may not have specifically informed respondents until March 2007 that he intended to remove the exterior stucco, when he had actually conducted stucco removal work during the early part of 2007, is irrelevant — by 2007 respondents had repeatedly received notice but had taken no action to correct the construction repair defects, prepare for negotiation or litigation, or safeguard against stale claims. See id. at 70.

It is also noteworthy that appellant had only a two-year window from the time he received notice of the problem in which to assert a claim, because the statute of limitations for such claims is two years from the date of discovery of the “injury.” Minn.Stat. § 541.051, subd. 1 (2008) (setting forth two-year statute of limitations for tort claims arising out of construction defects); see also Minn.Stat. § 327A.08 (2008) (stating that statutory warranties for home improvements apply only when the party providing a home improvement is given notice of a defect within six months of discovery of a work defect). Respondents may have had little motivation to respond during the period that appellant attempted to notify them of the continuation of the mold and water problem, but their dilatory tactics should not give them a legitimate spoliation claim.

Further, sanctioning a party for destruction of evidence “is only appropriate if the unavailability of the evidence results in prejudice to the opposing party.” Foss v. Kincade, 766 N.W.2d 317, 323 (Minn.2009); see Patton v. Newmar Corp., 538 N.W.2d 116, 119 (Minn.1995) (stating that spoliation sanction should be tailored to address “the impact of spoliation — the prejudice to the opposing party”). In crafting a spoliation sanction, the court must “examine the nature of the item lost in the context of the claims asserted and the potential for remediation of the prejudice.” Foss, 766 N.W.2d at 323 (quoting Patton, 538 N.W.2d at 119). In Foss, the supreme court ruled that homeowners’ disposal of a bookcase that had fallen on a visiting child did not merit a discovery sanction in a negligence action brought against the homeowners, because the bookcase had no evidentiary value and its disposal did not prejudice the plaintiffs. Foss, 766 N.W.2d at 324. Here, neither Donnelly nor the other respondents have shown that they were unable to determine the nature of appellant’s claims or their response to them because of any lack of evidence in the record. As in Foss, they have not shown that they suffered prejudice as the *744result of appellant’s 2007 repair work to his home.

In addition, the record includes 21 photographs taken of the exterior of appellant’s home in 2007 after the stucco was removed that, while black and white, clearly show the condition of the walls, including the presence of mold, and the record also includes the observations of various witnesses who observed the condition of the home. Under these circumstances, the sanction of exclusion of appellant’s evidence resulting in dismissal of his claim against all parties was simply wrong. Of particular concern is the court’s dismissal of appellant’s misrepresentation and warranty claims against the previous homeowners, which were independent of any dispute regarding workmanship of the contractors.

The threat of a spoliation sanction encourages an injured party to inform an alleged tortfeasor of a possible claim in order to enable the tortfeasor to defend against such a claim. Respondents were given that opportunity here, and the district court abused its discretion by imposing a spoliation sanction that extinguished appellant’s claim.