Justia Maine Supreme Court Opinion Summaries

A Massachusetts resident was hired by a staffing company authorized to do business in Massachusetts and assigned to work for a New Hampshire corporation at a job site in Maine. The staffing company and the New Hampshire corporation had an agreement stating that the staffing company would provide employees, pay their wages and benefits, and handle workers’ compensation. The New Hampshire corporation supervised the employees on site. While working in Maine, the employee was injured. He filed a workers’ compensation claim in Massachusetts against the staffing company, which was settled.Subsequently, the employee filed a negligence lawsuit against the New Hampshire corporation in the Cumberland County Superior Court in Maine. The corporation moved for summary judgment, arguing that it was immune from suit under Maine’s Workers’ Compensation Act, specifically 39-A M.R.S. § 104, which provides immunity to employers using temporary help services under certain conditions. The Superior Court denied the motion, concluding that Massachusetts law governed the immunity issue, not Maine law, and that under Massachusetts law, the corporation was not immune. The corporation appealed.The Maine Supreme Judicial Court reviewed the denial of summary judgment, applying Maine’s choice of law rules. It determined that Massachusetts law governed the workers’ compensation immunity issue because Massachusetts had the most significant relationship to the parties and the occurrence. The Court further held that, under Massachusetts law, the New Hampshire corporation did not qualify for immunity because it was not contractually liable for workers’ compensation benefits to the injured employee. The Court affirmed the Superior Court’s denial of summary judgment, making clear that the corporation was not entitled to immunity from the employee’s negligence claim under the applicable law. View "Valmont-Oliver v. Envirovantage, Inc." on Justia Law

Carissa Daniels filed a complaint in August 2023 alleging that Patrick R. O’Brien committed timber trespass on her property by cutting trees and bushes. O’Brien’s homeowner’s insurer, MMG Insurance Co., initially defended him under a reservation of rights but later withdrew that reservation and settled the claim with Daniels. Daniels then moved to dismiss her complaint with prejudice as part of the settlement. O’Brien objected to both the settlement and the dismissal, arguing he should have the opportunity to defend against Daniels’s claim and thereby preserve a potential wrongful use of civil process claim against her.The Superior Court (Oxford County) held a hearing on the motions. During the hearing, MMG moved to intervene to support Daniels’s dismissal, while O’Brien moved to keep the matter on the court’s docket. The court granted Daniels’s motion to dismiss with prejudice in February 2025 and denied O’Brien’s motion for further findings of fact and conclusions of law. O’Brien then appealed, raising procedural objections and challenging MMG’s authority to settle over his objection.The Maine Supreme Judicial Court reviewed the case and found no abuse of discretion by the Superior Court in granting the dismissal with prejudice. The Court explained that under Maine Rule of Civil Procedure 41(a)(2), whether to allow a voluntary dismissal is within the trial court’s discretion and does not require a hearing unless evidence is taken. The Court further held that there was no procedural error, and that the merits of the settlement and MMG’s authority to settle were not at issue in this proceeding. The judgment of the Superior Court was affirmed. The main holding is that a trial court does not abuse its discretion by granting a plaintiff’s motion to dismiss with prejudice, even over a defendant’s objection based on potential future claims. View "Daniels v. O'Brien" on Justia Law

An individual, R., who had previously been placed under the guardianship of the Department of Health and Human Services due to multiple strokes and a diagnosis of moderate vascular dementia, petitioned to terminate his guardianship. R. resided in an assisted living facility, needed help with daily living activities, and demonstrated poor understanding of his own cognitive limitations. He was also expected to inherit a substantial sum, raising concerns about his susceptibility to financial exploitation. The Department sought to be appointed as his conservator, citing his impaired ability to manage his finances and personal affairs.The Cumberland County Probate Court consolidated R.’s petition to terminate the guardianship with the Department’s petition for conservatorship and held a hearing. After considering evidence, including testimony from medical providers and behavioral observations, the court denied R.’s request to terminate the guardianship and appointed the Department as his conservator, finding by clear and convincing evidence that R. remained incapacitated and in need of protection. R. appealed, arguing that the evidence did not support the Probate Court’s findings and that he received ineffective assistance of counsel because his attorney failed to obtain an independent psychological evaluation.The Maine Supreme Judicial Court affirmed the Probate Court’s judgment, holding that the evidence supported the denial of the petition to terminate guardianship and the grant of conservatorship. The court expressly recognized, for the first time, that individuals in guardianship or conservatorship proceedings have a right to the effective assistance of counsel, and adopted the Strickland v. Washington standard for evaluating such claims. The court articulated a procedure for raising ineffective assistance claims in these proceedings but found that R.’s claim lacked merit because he did not show that his counsel’s alleged deficiencies prejudiced the outcome. Judgment was affirmed. View "Adult Guardianship and Conservatorship of R." on Justia Law

A Maine resident was stopped while driving a pickup truck registered to a Montana limited liability company, not to himself personally. The officer confirmed that the company, Brandon McCoy, LLC, was active and properly registered in Montana, and that all of the resident’s vehicles were registered to that company. The officer had previously informed the resident that, as a Maine resident, he would need to register his vehicles in Maine. After observing a non-functioning taillight, the officer stopped the resident, confirmed his Maine residency, and issued him a summons for evasion of registration fees and excise taxes under Maine law, specifically 29-A M.R.S. § 514.The matter was first heard in the Maine District Court in Biddeford. At the hearing, both the officer and the resident testified. The District Court found that the resident had been twice warned about a registration requirement and adjudicated him responsible for the infraction, imposing the statutory minimum fine. The resident appealed this judgment.The Supreme Judicial Court of Maine reviewed the case and examined the statutory language. The Court determined that liability under section 514 attaches only to the “owner” of the vehicle, defined as the person holding title or having the exclusive right to use the vehicle for at least thirty days. The evidence indicated that the Montana LLC, not the resident, held title to the pickup, and there was no evidence that the resident had an exclusive right to its use for thirty days or more. The Court held that the resident was not required to register the vehicle under Maine law and could not be found in violation of section 514. The judgment against the resident was vacated, and the case was remanded for entry of judgment in his favor. View "State of Maine v. McCoy" on Justia Law

A married couple entered into a premarital agreement prior to their 2015 wedding. The agreement stated that each party’s property, including business interests owned prior to or acquired during the marriage, would remain separate and nonmarital. It also included a provision anticipating that the husband would purchase a condominium, which would become the marital home and, in the event of divorce, its value would be split equally. During the marriage, the couple resided in the condominium, but it remained owned by the husband’s mother, and the husband never purchased it. The couple separated in 2020, and the husband filed for divorce in 2021. Throughout the marriage, the husband acquired and managed various business interests, while both parties maintained separate finances.The Maine District Court in Portland held several hearings to resolve issues related to spousal support, discovery sanctions, and the interpretation and validity of the premarital agreement. The parties stipulated that the agreement was valid but disputed its scope, particularly regarding business interests and the condominium provision. The District Court found that the wife had waived any claim to the husband’s business interests and any increase in their value, and that the agreement did not require the husband to purchase the condominium. The court also determined it lacked jurisdiction to consider the wife’s breach-of-contract claim regarding the condominium and awarded her a portion of her requested attorney fees.Upon appeal, the Maine Supreme Judicial Court vacated the District Court’s judgment in part. It held that the wife had clearly waived any claim to the husband’s business interests and their increases in value. However, the Supreme Judicial Court determined that the lower court erred in concluding it lacked jurisdiction over the breach-of-contract claim concerning the condominium and in interpreting the agreement as not requiring its purchase. The case was remanded for further proceedings consistent with these holdings. View "Hutchinson v. Gomez" on Justia Law

Amelia Johnson sought a protection-from-abuse order for herself and her minor child against Michael Osseyran, the child’s father. She filed her complaint in December 2024, alleging that Osseyran’s actions toward her and their child constituted abuse. The court issued a temporary protection order and temporarily awarded Johnson parental rights. At a final hearing, Johnson testified about incidents where Osseyran physically disciplined the child, describing grabbing and yelling. An investigations caseworker from the Department of Health and Human Services and a friend of Osseyran’s also testified. The court reviewed evidence including text messages between the parties.The District Court (Portland) found that while the parties’ child was difficult to parent and Osseyran’s actions may have been offensive, Osseyran had not engaged in stalking, threatening, or harassing behavior toward Johnson or the child. The court concluded that his actions were attempts to parent, not abuse, relying on statutory language that allows a parent to use a reasonable degree of force when disciplining a child. The court declined to issue a final protection-from-abuse order and dismissed the temporary order. Johnson appealed, arguing that the evidence required a finding in her favor, the District Court misapplied the statute, and that it had admitted inadmissible hearsay evidence.The Maine Supreme Judicial Court reviewed the case. It held that the evidence did not compel a finding that Johnson was entitled to a protection-from-abuse order, that the District Court correctly interpreted the statutory definitions of abuse, and that although hearsay evidence was admitted in error, it did not result in prejudice warranting reversal. The Court modified the judgment to correct a clerical error regarding the parties’ attendance at the hearing but otherwise affirmed the District Court’s judgment. View "Johnson v. Osseyran" on Justia Law

A woman and a man, both originally from the Middle East, met in the United States and traveled to Dubai, United Arab Emirates, in 2019 for a religious marriage ceremony conducted remotely by an imam in Maine. No religious official was present in person in Dubai. The ceremony followed Islamic traditions, and the imam issued a certificate of religious marriage. The couple later held a wedding reception in Turkey, where they and two witnesses signed the certificate. They returned to Maine but did not complete any ceremony or licensing required by Maine law, though the woman attempted unsuccessfully to certify the marriage at a local city hall before filing for divorce.The woman then filed for divorce in the Maine District Court in 2024. The man moved to dismiss, arguing there was no lawful marriage. After an evidentiary hearing, the District Court (Biddeford) granted the motion, finding the parties had not complied with Maine’s marriage statutes and were not legally married in Maine or elsewhere. The court also rejected the argument that any exception under Maine law applied, and dismissed the divorce complaint. The woman timely appealed.The Maine Supreme Judicial Court reviewed the case and held that the validity of a marriage is determined by the law of the jurisdiction where the marriage ceremony occurred, not Maine law, unless the marriage is contrary to Maine’s basic public policies. Since the ceremony was in Dubai, the question was whether the marriage was valid under the laws of the United Arab Emirates. The Court found that the woman had not addressed this question at trial or on appeal and therefore waived the argument. The Maine Supreme Judicial Court affirmed the District Court’s judgment dismissing her complaint for divorce. View "Aldarraji v. Alolwan" on Justia Law

The defendant was charged with multiple offenses, including domestic violence aggravated assault, following an incident on May 12, 2021, in which she was alleged to have strangled her roommate and caused significant injuries. After being indicted on several charges, including attempted murder, the defendant reached an agreement to plead guilty to domestic violence aggravated assault, with the other charges dismissed and sentencing to be determined by the court. At the combined plea and sentencing hearing, the State described its evidence, including the victim’s account of repeated strangulation, and submitted an expert report on the victim’s injuries. The defendant, through counsel, acknowledged responsibility for the incident but limited her admission to the initial report of a single assault and did not contest additional details provided by the victim or the expert.The Cumberland County Unified Criminal Docket accepted the guilty plea and proceeded to sentencing. The State recommended a significant term of incarceration based on multiple incidents of strangulation and serious injury, while the defendant argued for a suspended sentence, citing her personal progress, lack of criminal history, and the risks of incarceration as a transgender individual. The court followed the statutory three-step sentencing process, considered both aggravating and mitigating factors, and imposed a seven-year sentence with all but four years suspended and three years of probation. The defendant appealed, arguing that her due process rights were violated when the sentencing court relied on unsworn victim statements and an expert report without cross-examination.The Supreme Judicial Court of Maine reviewed the case, applying de novo review to constitutional claims but only for obvious error due to the lack of contemporaneous objection. The Court held that due process does not require cross-examination or sworn testimony at sentencing so long as the information considered is reliable and the defendant has an opportunity to contest it. The Court found no obvious error and affirmed the judgment. View "State of Maine v. Miller" on Justia Law

Three neighbors who own properties in a Wells subdivision hold easement rights over a ten-foot-wide right-of-way that crosses the property of another couple, the Linds, to access the Webhannet River. One neighbor’s deed includes the easement, while another’s does not, but the trial court determined both benefit from an implied easement and Maine's “paper streets” statutes. In 2023, the Linds installed a split-rail fence along the center of the right-of-way and constructed a driveway partly within it. The neighbors, who use the easement to carry items such as kayaks to the river, claimed that the fence and parked vehicles unreasonably interfered with their easement rights.The neighbors filed suit in the York County Superior Court, seeking declaratory and injunctive relief. The court required joinder of another abutting property owner, then considered cross-motions for summary judgment. It concluded that while the Linds’ parking vehicles in the right-of-way did materially impair pedestrian access and thus interfered with the easement, the split-rail fence did not, as the neighbors could still access the river. The court denied the neighbors’ request for summary judgment and granted the Linds’ in part, resulting in a final judgment after dismissal of another claim.On appeal, the Maine Supreme Judicial Court reviewed the summary judgment ruling de novo. The court held that the fence, by splitting the right-of-way and reducing practical access to half its width, unreasonably interfered with the neighbors’ easement rights as a matter of law, even if some access remained. It distinguished prior precedent involving minor obstructions and reaffirmed that easement holders are entitled to use the full described width for the easement’s purposes. The Supreme Judicial Court vacated the summary judgment and remanded for further proceedings on injunctive relief. View "Lytle v. Lind" on Justia Law

A married couple acquired real estate in Bucksport, Maine, during their marriage and operated a short-term rental business on the property through a jointly owned limited liability company (LLC). They also owned a 2009 SeaRey airplane, acquired during their marriage. After the wife obtained a protection from abuse order against the husband in June 2022, she operated and maintained the business and prepared the real estate for sale without his involvement. The parties reached a partial settlement on some divorce issues, but disputed the division of the Bucksport property, the status and value of the airplane, and the dissolution of the LLC.The District Court in Bangor entered a divorce judgment incorporating the parties’ partial agreement. The court awarded the wife 60% of the value of the Bucksport real estate, attributing the increase in value to her post-separation efforts. It determined the airplane was marital property used primarily for personal purposes, valued it at $37,500, and awarded it to the husband, requiring him to compensate the wife for her share or to sell and divide the proceeds. The court also ordered the dissolution of the LLC and distribution of any profits. The husband appealed, challenging the division of real estate, the airplane’s use and valuation, and the dissolution of the LLC.The Maine Supreme Judicial Court affirmed the District Court’s finding that the airplane was marital property and not a business asset, but vacated the valuation of the airplane, finding insufficient evidence to support the assigned value. The Court also held that the District Court lacked jurisdiction to order dissolution of the LLC as part of the divorce. The judgment was vacated as to the distribution of the Bucksport real estate, the airplane’s valuation, and the LLC dissolution, and the case was remanded for further proceedings consistent with these rulings. The divorce judgment was otherwise affirmed. View "Adams v. Delong" on Justia Law