Moore v Beye

Legal Case Brief
Name
Institutional Affiliation
Legal Case Brief
Brief of Moore V. Beye
Dennis Moore
v.
Ronald Beye
329 Mont. 109, 122 P.3d 1212
Assault & battery case
Facts
Dennis Moore and Ronald Beye were involved in an altercation while at a public meeting of the Ravalli County Commissioners. Moore, an owner of a ranch near the airport in Ravalli County, opposed the expansion of the airport while Beye who owned a flying service based at the airport supported the expansion. Moore and Beye exchanged un-pleasantries after the meeting, and the later punched the former on the left side of the jaw. Beye was arrested and charged with misdemeanor assault. Though Moore caught himself before hitting the ground, two days later, he visited the hospital for neck and back pains and medical reports revealed that he suffered a lumbar strain and facial bruise. However, Moore insisted that he injured his back while reeling from the punch and visited several doctors for treatment. Moore later filed a complaint against Beye alleging back and neck injuries and sought damages for the emotional distress suffered. Beye pleaded guilty for punching Moore and a jury trial to determine damages held that Moore was not damaged by the battery. Moore filed a motion to vacate jury award and receive a new trial, but the District Court denied the motion according to Rule 59, M.R.Civ.P., and § 25-11-102(6), MCA, on July 22, 2004.
Issue
The issue is whether the evidence presented by Beye, which the jury used to rule that Moore was not damaged by the battery was “substantial credible evidence” even though it was “weak and conflicted” or it was “trifling or frivolous evidence.

”
Holding
The Supreme Court held that even though Moore’s evidence was cited with several conflicts, it was not “trifling or frivolous evidence” and was therefore “substantial credible evidence,” which the court could not reverse.
Reasoning
The defendant admitted fault for the assault but denied and contested causing any damages just like in Thompson v. City of Bozeman (1997) and Renville v. Taylor (2000). In the mentioned cases, the jury awarded zero damages to the plaintiffs, and the court held that their decision was contrary to the evidence. In the case at hand, the uncontroverted evidence presented showed that Moore was injured to some degree and thus the jury was in error to award him Zero damages. In spite of the similarities between the cases, the court noted that;
The conflicting evidence is in whether caused Moore any injury worth a settlement.
The jury in the Moore v. Beye case was not instructed to find the extent of the damage caused by the assault on the plaintiff but to determine whether the plaintiff was damaged as a result of the battery to which the response was no.
The motion did not indicate any error in how the jury was instructed.
Unlike in the previous similar cases where the jury awarded special damages for injuries and medical expenses to the plaintiffs in spite of contestation on the cause, no damages were awarded to Moore.
Therefore, there was no discrepancy in the Moore v. Beye case since the jury did not recognize any injuries on the plaintiff yet fail to award damages.
References
Moore v. Beye. No. 04-870. (2005). 329 Mont. 109, 122 P.3d 1212
Renville v. Taylor. (2000). MT 217, 301 Mont. 99, 7 P.3d 400
Rule 59, M.R.Civ.P., and § 25-11-102(6), MCA, on July 22, 2004
Thompson v. City of Bozeman. (1997). 284 Mont. 440, 945 P.2d 48