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Sentencing Guidelines

WI Court of Appeals – District I

Case Name: Mid America Steel Drum Properties, LLC v. Container Life Cycle Management LLC

Case No.: 2021AP001603

Officials: Brash, C.J.

Focus: Unjust Enrichment

Container Life Cycle Management LLC appeals the judgment and order entered in favor of Mid America Steel Drum Properties, LLC, a reconditioner of steel drums, and 17H LLC (collectively, Mid America), upon a jury verdict which found that Container Life had committed trespass and unlawfully withheld possession of several parcels owned by Mid America, and was unjustly enriched by that conduct. Container Life argued that it thought those parcels were included in a lease it had entered into with Mid America. It therefore filed a counterclaim for reformation of that lease to include one parcel in particular, referred to as the “Trailer Yard,” in the lease; that counterclaim was dismissed by the trial court.

On appeal, Container Life contends that the trial court erred in dismissing its counterclaim to reform the lease. Container Life also asserts that the trial court erroneously exercised its discretion with regard to several issues relating to jury instructions and the special verdict, as well as its denial of Container Life’s motion to bifurcate the trial to address the equitable issue of lease reformation prior to addressing the legal claims presented by Mid America.

The appeals court concludes that the trial court did not erroneously exercise its discretion in any of the decisions being challenged by Container Life, and also rejects Mid America’s argument in its cross-appeal that the trial court applied the wrong legal standard in considering its punitive damages claim.

Affirmed.

Decided 01/18/23

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