Justia Maine Supreme Court Opinion Summaries

Neils Point, LLC owns a farm property in Harpswell, Maine, which it leased to Joseph and Laura Grady for agricultural use. The Gradys resided on the property and operated the farm under successive lease agreements, culminating in a 2017 extension titled “Commercial Agricultural Lease Agreement.” This lease specified that it was not a residential rental, set rent as a percentage of the farm’s net proceeds, and required arbitration for disputes. Neils Point alleged that the Gradys breached the lease by miscalculating rent, failing to pay on time, and not using the land as productive cropland.After Neils Point initiated arbitration in 2024, the Gradys responded by admitting the dispute was subject to arbitration and made their own arbitration demand under the lease. The arbitration hearing was held in July 2025, with both parties participating fully and without objection to either the process or the arbitrability of the dispute. The arbitrator found in favor of Neils Point, concluding that the Gradys breached the lease by improperly deducting expenses, failing to pay rent, and not maintaining the farm’s productivity. Damages were awarded, and the Gradys were ordered to vacate the property.The Cumberland County Superior Court confirmed the arbitration award and denied the Gradys’ subsequent motion to vacate, in which they argued for the first time that the arbitration provision was void because the lease was residential and the arbitrator exceeded his authority. The Maine Supreme Judicial Court affirmed the judgment, holding that the Gradys’ participation in arbitration without objection waived their right to challenge the validity of the arbitration clause or the arbitrator’s authority. The Court further held that the arbitrator’s construction of the lease was rational, and thus confirmation of the award was proper. View "Neils Point, LLC v. Grady" on Justia Law

A condominium resident entered into an agreement with the developer, the unit owners’ association, and other unit owners after concerns were raised about infrastructure and proposed changes to the condominium plan. The agreement required the developer to complete infrastructure work, pay a sum to the association, and convey a vacant lot to the association in exchange for the unit owners withdrawing their opposition to a planning board application. The agreement included a provision requiring planning board approval of the developer’s application by March 1, 2023, as a condition for the parties’ obligations. The planning board, however, did not approve the application until March 28, 2023. After learning that the lot was to be sold to a third party, the resident sued for specific performance of the agreement.The Superior Court (York County) granted the developer’s motion to dismiss, ruling that the failure to obtain planning board approval by the specified date was an unmet condition precedent, discharging all parties from their obligations under the agreement. The court also dismissed the resident’s claims for quantum meruit, unjust enrichment, and declaratory relief on independent grounds.On appeal, the Maine Supreme Judicial Court reviewed whether the timing requirement for planning board approval was necessarily a material condition precedent as a matter of law. The Court held that, in actions seeking equitable relief such as specific performance, whether time is of the essence is a factual question dependent on the intent of the parties and the circumstances. The Court concluded that the materiality of the March 1 deadline could not be determined solely from the pleadings, and that the complaint alleged facts which, if proven, could entitle the resident to relief. The Court vacated the dismissal of the breach of contract claim and remanded for further proceedings. View "Constance L. Beane v. Village on Great Brook, LLC" on Justia Law

The case involves a dispute between Pat Doe and Alexander Y. Miller concerning allegations of abuse and child custody. After a series of contentious interactions and alleged misconduct by Miller—including threatening behavior, stalking, and interference with Doe’s property and finances—Doe sought protection from abuse for herself and her three children. Previous legal proceedings related to these matters took place in Maryland and Connecticut, with varying outcomes. At the time Doe sought relief in Maine, Miller resided in that state, while Doe and the children lived in Maryland but were temporarily in Maine to address legal and property issues.The Maine District Court entered a temporary protection order for Doe but not for the children. The court was aware of ongoing related proceedings in Maryland and Connecticut. Ultimately, the Maine District Court dismissed Doe’s complaint, finding it lacked personal jurisdiction over Doe and, under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), lacked jurisdiction over the children since a Connecticut order was in effect when Doe filed in Maine. The court also reasoned that Doe had already submitted to Connecticut’s jurisdiction and could not start a new proceeding in Maine on the same grounds.Upon review, the Maine Supreme Judicial Court held that the District Court erred in dismissing Doe’s complaint for lack of personal jurisdiction because Doe, as the plaintiff, had consented to jurisdiction by filing the complaint, and the existence of another proceeding was not a sufficient reason for dismissal. Regarding the children, the Supreme Judicial Court determined the District Court failed to follow the mandatory UCCJEA procedure of communicating with the other courts to determine proper jurisdiction. The Supreme Judicial Court vacated the dismissal and remanded the case for further proceedings, directing the District Court to address Doe’s claims and engage in proper UCCJEA procedures regarding the children. View "Doe v. Miller" on Justia Law

John Veneziano obtained a $3,500,000 money judgment against Bernard J. Saulnier in the United States Bankruptcy Court for the District of Maine. Veneziano then sought to enforce this judgment in Maine state court by filing a disclosure subpoena and related documents in the District Court in Biddeford. The case was later transferred to the Business and Consumer Docket. After discovery disputes and a disclosure hearing, the Business and Consumer Docket found that Saulnier’s actual earnings allowed for weekly installment payments of $1,009 and ordered Saulnier to make those payments to satisfy the judgment.Following this order, Saulnier appealed, initially contesting the imputation of income above his reported earnings. During the appeal, the Maine Supreme Judicial Court raised the issue of whether the federal judgment had been domesticated in Maine, as required by statute. The parties provided supplemental briefing on the issue. It was undisputed that the federal judgment had not been domesticated in Maine state court pursuant to the Uniform Enforcement of Foreign Judgments Act.The Maine Supreme Judicial Court held that the Business and Consumer Docket lacked subject-matter jurisdiction to enforce an undomesticated federal judgment. The court concluded that Maine’s disclosure statute authorizes enforcement only of judgments entered in Maine state courts, and that a foreign or federal judgment must first be domesticated in Maine before it may be enforced through disclosure proceedings. Because domestication had not occurred, the Business and Consumer Docket had no authority to act, and its order was vacated. The case was remanded with instructions to dismiss the action for lack of jurisdiction. View "Veneziano v. Saulnier" on Justia Law

The defendant was charged with multiple offenses, including three counts of gross sexual assault, two counts of unlawful sexual contact, two counts of unlawful sexual touching, and one count of tampering with a witness or informant. The offenses involved sexual abuse spanning several years against a young girl, who had a close, grandfather-granddaughter-like relationship with the defendant. The abuse primarily occurred at the defendant’s home, where he lived with his grandson. Law enforcement began investigating after the victim disclosed the abuse in 2018. Initially, the defendant’s grandson denied witnessing any abuse but later recanted and confirmed having seen inappropriate conduct and being coached by the defendant on what to say.Following the investigation, the State indicted the defendant on several charges, later expanded by a superseding indictment. Prior to trial, the State sought to admit a noncriminal pornographic photograph found on the defendant’s computer, depicting a sexual act between a young female and an older male, captioned “Oh, Grandpa!” The trial court granted the defendant’s motion to sever certain counts, excluding some images but admitting the specific photograph as evidence of motive and intent. The court also allowed testimony about alleged uncharged conduct occurring outside Maine, after the defendant’s counsel affirmatively stated there was no objection. A jury found the defendant guilty on the charges tried, and he was sentenced accordingly.On appeal to the Maine Supreme Judicial Court, the defendant challenged the admission of the photograph and the testimony about uncharged conduct. The Supreme Judicial Court held that the trial court did not abuse its discretion in admitting the photograph, as it was relevant to prove motive and intent for the charges requiring intent, and was not unduly prejudicial. The Court also concluded that the argument regarding uncharged conduct was waived by the defendant’s lack of objection. The judgment of conviction was affirmed. View "State of Maine v. Marin" on Justia Law

The Maine Human Rights Commission filed a lawsuit in the Superior Court alleging that a landlord discriminated against his tenant based on sex, asserting claims under both the Maine Human Rights Act and the Fair Housing Act. After litigation began, the tenant requested a judicial settlement conference. The landlord did not attend the conference, but his attorney and daughter attended, allegedly with his authority to settle. After the conference, a record form stated that the parties had agreed to a full and final settlement, but disagreements arose during subsequent exchanges of draft settlement agreements, particularly over provisions related to an acknowledgment of antidiscrimination laws and certain “public-relief terms” such as fair-housing training and property management oversight.The Kennebec County Superior Court reviewed a motion to enforce the settlement agreement. Without holding an evidentiary hearing, the court found that the parties intended to be bound by an agreement reached at the settlement conference, as reflected in the settlement conference record form. The court identified five basic terms as the substance of the agreement, including a payment to the tenant and specific non-monetary provisions. The court ordered the parties to execute an agreement consistent with these terms, except for the acknowledgment provision, which it found was not part of the agreement.On appeal, the Maine Supreme Judicial Court found that the record was insufficient to support the Superior Court’s finding that the parties mutually assented to all material terms of a binding settlement agreement. The Supreme Judicial Court held that, in the absence of an evidentiary hearing or a sufficiently detailed record, the lower court erred in enforcing the settlement. The Supreme Judicial Court vacated the judgment and remanded the case to the Superior Court for an evidentiary hearing to determine whether the parties actually reached a binding agreement and, if so, its precise terms. View "Maine Human Rights Commission v. Larkin" on Justia Law

A candidate for Knox County Sheriff submitted the required election petition and consent form, swearing to meet statutory qualifications for the office, including at least two years of supervisory employment experience in law enforcement or corrections. He provided documentation and testimony from his previous employer, the Chattanooga Housing Authority Police Department, confirming his supervisory role over contract officers. A registered voter and deputy sheriff challenged the candidate’s qualifications, particularly contesting the sufficiency of his supervisory experience. At the hearing, the candidate declined to testify, but his former supervisor and a contract officer testified about his supervisory duties.A presiding officer appointed by the Secretary of State heard the challenge and found that the candidate’s position did not constitute sufficient supervisory employment experience under the relevant statute, reasoning that his supervisory authority was limited and primarily over independent contractors rather than employees. The officer recommended that the candidate’s consent form be invalidated. The candidate objected to this recommendation.The Secretary of State issued a final decision, adopting the presiding officer’s findings regarding certification but concluding that the candidate’s supervisory experience as a Criminal Investigator satisfied the statutory requirement. The Secretary of State interpreted supervisory employment experience to mean supervision of personnel as a job responsibility, regardless of whether the supervised individuals were direct employees or contractors. On appeal, the Maine Supreme Judicial Court reviewed the interpretation of the statute de novo and the Secretary of State’s factual findings for substantial evidence. The Court held that the Secretary of State’s interpretation and application of the statute were correct and supported by substantial evidence, and affirmed the decision allowing the candidate to appear on the ballot. View "Landers v. Secretary of State" on Justia Law

After Robert R. Young Sr.’s death in 2017, a dispute arose among his children over which of two documents should control the distribution of his estate. In 2000, Robert Sr. executed a formal will prepared by his attorney, leaving his business to his son Raymond, dividing other assets, and leaving only one dollar to his son Robert Jr. The day before his death, following a contentious conversation with Robert Jr., Robert Sr. handwrote a two-page document outlining a new distribution plan, including bequests to charity and his daughter Dianne Parker. He told Robert Jr. that he intended to take this handwritten note to his attorney to make it into a “permanent will.” Robert Sr. died the next day before doing so.Raymond initiated probate proceedings in the Waldo County Probate Court, asking to admit the 2000 will. Robert Jr. and Parker sought to probate the 2017 handwritten document as a holographic will. In a separate action in the Waldo County Superior Court, Raymond’s claims of undue influence by Robert Jr. and Parker were rejected on summary judgment. The Probate Court held a bench trial and found that Robert Sr. did not intend the handwritten 2017 document to serve as his will, but rather as notes for his attorney. The court denied probate of the 2017 document and admitted the 2000 will.The Maine Supreme Judicial Court reviewed the case and affirmed the Probate Court’s order. The Court held that the Probate Court properly considered extrinsic evidence regarding testamentary intent under 18-C M.R.S. § 2-502(3), that competent evidence supported the finding that Robert Sr. lacked testamentary intent for the 2017 document, and that the appellants’ due process rights were not violated by the trial proceedings. The order denying probate of the 2017 document and allowing the 2000 will was affirmed. View "Estate of Young" on Justia Law

Following a domestic dispute on July 28, 2024, Steven A. Truman was arrested in Kennebec County, Maine, for domestic violence aggravated assault involving his girlfriend, A.D., after law enforcement observed physical marks on her. Upon being jailed, Truman was ordered not to contact A.D. and signed a form acknowledging this condition. Despite the order, Truman called A.D. from jail, during which he encouraged her to provide a false explanation for her injuries. The State indicted Truman for victim tampering and improper victim contact. Meanwhile, the original assault charges against him were dismissed before his trial on the tampering charge.The Kennebec County Unified Criminal Docket presided over pretrial motions, including Truman’s requests to inspect the victim witness advocate’s records and exclude references to A.D. as a “victim,” which were denied. At trial, the court admitted jail call recordings over Truman’s objections. The jury heard testimony from the District Attorney’s investigator and the victim witness advocate. Truman’s motions for acquittal and mistrial, based on arguments about the definition of “victim” and alleged prejudicial use of the term, were denied. The jury convicted Truman on both counts, and his post-trial motion for a new trial was also denied.The Maine Supreme Judicial Court reviewed Truman’s appeal, which challenged the statutory interpretation of “victim,” evidentiary rulings, denial of in camera review, and alleged prosecutorial error. The Court held that, under Maine law, the State need not prove the underlying crime for a victim tampering conviction; it suffices that the person was the alleged victim in a pending investigation or proceeding. The Court affirmed the trial court’s evidentiary decisions, denial of in camera review, and found no prejudicial prosecutorial error. The conviction was affirmed. View "State of Maine v. Truman" on Justia Law

In January 2011, a sixteen-year-old girl was driven by her thirty-seven-year-old cousin from Fort Kent to Bangor during a family emergency. During the drive, the cousin asked her inappropriate sexual questions and touched her breasts, leg, and genitals over her clothes. Later, at a relative’s apartment, he exposed himself to her and threatened to harm her family if she disclosed the events. More than a decade later, the woman initiated a lawsuit against her cousin for negligence, negligent infliction of emotional distress (NIED), and intentional or reckless infliction of emotional distress (IIED), seeking damages for the harm she suffered.The Penobscot County Superior Court held a bench trial and found in favor of the plaintiff, awarding her one million dollars in damages. The court found the defendant liable on all three claims. The defendant appealed, arguing that the statute of limitations barred the claims and that the plaintiff had not met her burden of proof.The Maine Supreme Judicial Court reviewed the case and held, first, that the claims were not barred by the statute of limitations because state law permits actions based on certain sexual acts toward minors to be brought at any time, and the defendant’s conduct met the required statutory definitions. On the merits, the Court concluded that the evidence was insufficient to support liability for negligence and NIED, as the plaintiff did not establish the type of physical injury required for negligence, nor did the relationship between the parties rise to the level required for NIED. However, the Court affirmed the finding of liability for IIED, determining that the defendant’s conduct was so extreme and outrageous that severe emotional distress could be inferred. The Court vacated the judgment on the first two counts and affirmed the judgment on the IIED claim. View "Nadeau v. Nadeau" on Justia Law