Opinion
Argued September 18, 1984.
Decided October 29, 1984.
Appeal from the Superior Court, Androscoggin County.
Thomas M. Mangan (orally), Lewiston, for plaintiff.
Stephen T. Hayes (orally), Augusta, for defendant.
Before McKUSICK, C.J., and ROBERTS, VIOLETTE, WATHEN, GLASSMAN, and SCOLNIK, JJ.
MEMORANDUM DECISION.
Kenneth Bryant appeals from a judgment of the Superior Court, Androscoggin County, entered upon a jury verdict awarding the plaintiffs punitive damages. The defendant claims error in the court's instructions for the first time on appeal. Despite the defendant's failure to make objection at trial as required by M.R.Civ.P. 51(b), this court will review the trial court's instructions for obvious error prejudicing substantial rights of the defendant. Knight v. Penobscot Bay Medical Center, 420 A.2d 915, 919 (Me. 1980); 1 Field, McKusick Wroth, Maine Civil Practice § 51.2 (2d ed. 1970 Supp. 1981). The defendant argues that this court should apply a less rigorous standard of review than obvious error in view of his self-representation at trial. This we decline to do.
Finding no prejudicial error in the instructions of the trial court, we affirm the judgment.
The entry is:
Judgment affirmed.
All concurring.