Funk v. WilcoxAnnotate this Case
In this dispute over the distribution of settlement proceeds that arose out of litigation regarding the Pine Creek Fire in August 2012, the Supreme Court affirmed the order of the district court approving the special master’s recommendation for allocating the Pine Creek Fire settlement proceeds among the Funks, the Pitmans, the Wilcoxes, and four other plaintiffs, holding that the district court did not clearly err by adopting the special master’s factual findings.
Seeking to recover damages for injuries the Pine Creek Fire caused, the Funks, Pitmans, Wilcoxes, and four other property owners brought negligence claims against multiple defendants. The parties agreed to a settlement, and because the settlement proceeds could not cover all the plaintiffs’ damages, the district court appointed a special master to allocate the settlement proceeds. Of the settlement proceeds, the special master awarded approximately sixty-six percent to the Wilcoxes, twenty-four percent to the Funks, and three percent to the Pitmans. The district court adopted the special master’s recommendations for allocating the settlement funds. The Supreme Court affirmed, holding that the special master did not commit a clear error by finding that the Wilcoxes lost sixty acres of forested land during the fire.