Justia Maine Supreme Court Opinion Summaries

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

John M. Carter and Ann C. Martin were married in 2015. Carter initiated divorce proceedings in March 2023. On June 6, 2025, a hearing was held in the Maine District Court, at which both parties testified remotely. The court orally announced that the divorce would be final as of that day if both parties filed waivers of appeal. Carter filed his waiver that same day, but Martin did not. The court determined that additional real estate orders were needed before finalizing the judgment. Before the court signed the final written judgment and the real estate orders on July 3, 2025, Carter died on June 27, 2025.Following Carter’s death, Martin filed a motion for relief from or to alter the judgment, arguing that the court lacked jurisdiction to enter a final divorce judgment after Carter’s death. The District Court denied her motion, citing Boland v. Belair, and reasoned that the settlement the parties had reached should be binding. Martin then appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the case de novo and held that because Carter died before the court signed the final judgment, the marriage was automatically terminated by death. Therefore, the District Court no longer had subject matter jurisdiction to enter a divorce judgment, as there was no longer a marriage to dissolve. The Supreme Judicial Court ruled that the judgment signed after Carter’s death was void and that the use of nunc pro tunc was not valid to retroactively finalize the divorce. The court vacated the District Court’s judgment and remanded the case with instructions to dismiss the divorce action. View "Estate of Carter v. Martin" on Justia Law

A woman was struck and injured by a bus in Bangor, Maine. The bus was operated as part of a public transit system known as the Community Connector, which serves several municipalities and the University of Maine. The City of Bangor oversees daily operations of the Community Connector, but the precise extent of involvement by the neighboring towns and cities is disputed. It is also unclear whether the bus that struck the plaintiff was running on a Community Connector route or a Bangor-only route; the buses for both services look the same.The plaintiff filed a complaint in the Penobscot County Superior Court against the City of Bangor, the Community Connector, and several neighboring towns and cities, alleging negligence and asserting that the Community Connector operated as a joint venture among the defendants. The municipalities moved for summary judgment, arguing they were immune from suit under the Maine Tort Claims Act. The Superior Court denied summary judgment, holding that the municipalities had not established that there were no material disputes of fact regarding their involvement or possible joint venture status. The court also denied a motion for reconsideration.On appeal, the Maine Supreme Judicial Court considered whether the municipalities were entitled to immunity as a matter of law. The Court found that key factual questions remained unresolved, including whether the municipalities exercised direct control over the bus or its driver and the nature of their participation in the Community Connector. Because these factual disputes must be resolved by the trial court before determining the applicability of immunity, the Maine Supreme Judicial Court dismissed the appeal as interlocutory, leaving the issue of immunity to be addressed after further factual development in the trial court. View "Fisher v. Town of Hampden" on Justia Law

A condominium unit was owned by Diane Marchetti, who did not reside in the unit but allowed her daughter, Caroline Thibeault, and Thibeault’s son to occupy it. The condominium’s association initiated a foreclosure action against Marchetti alleging she was in default for failing to pay assessments, fines, and fees—some of which related to Thibeault’s alleged commercial use of the unit. Thibeault’s son has a disability, and both Thibeault and Marchetti asserted that the association had failed to provide reasonable accommodation under federal and state disability laws.After the foreclosure action commenced in the Sagadahoc County Superior Court, Marchetti filed an answer and raised several defenses, including alleged violations of the Americans with Disabilities Act and the Maine Human Rights Act. Thibeault, who was not a party to the action, then moved to intervene, claiming both a direct interest in the property and statutory civil rights at stake. She sought intervention as of right or, alternatively, permissive intervention, arguing her interests were not adequately represented and that her defenses raised common questions of law and fact with the main action. The Superior Court denied her motion to intervene on both grounds, finding her interest insufficient and noting that her mother’s defenses already encompassed her concerns.The Maine Supreme Judicial Court reviewed the order denying intervention. The court held that Thibeault did not satisfy the criteria for intervention as of right under Maine Rule of Civil Procedure 24(a)(2) because she lacked a direct, legally protectable interest in the foreclosure action, her ability to protect her interests would not be impaired by denial, and her interests were adequately represented by Marchetti. The court also found no abuse of discretion in denying permissive intervention under Rule 24(b) because Thibeault’s participation would be duplicative and cause undue delay. The order denying intervention was affirmed. View "Oak Hill Condominiums v. Marchetti" on Justia Law

Fifth Generation, Inc., a Texas-based liquor manufacturer and subchapter S corporation known for producing Tito’s Vodka, supplied increasing quantities of vodka to Maine between 2011 and 2017 without filing Maine pass-through-entity withholding or income tax returns. The company did not own real estate or hold itself out as doing business in Maine but shipped its products to a Maine state-operated bailment warehouse, as required by state law. Fifth Generation retained title to the goods in the warehouse until they were sold to the Maine Bureau of Alcoholic Beverage and Lottery Operations, and its out-of-state employees and broker occasionally accessed the warehouse.Maine Revenue Services conducted an audit and assessed over $748,000 in withholding, interest, and penalties against Fifth Generation. The company appealed to the Maine Board of Tax Appeals, which found no income tax nexus and canceled the assessment. The State Tax Assessor then sought de novo review in the Maine Superior Court (Kennebec County), which granted summary judgment for the Assessor, reinstating the assessment. Fifth Generation subsequently appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court held that Fifth Generation was not exempt from state income tax during the audit period. The Court found that, under Maine law, Fifth Generation had a sufficient nexus with Maine because it owned tangible property in the state and sold it there. The Court also concluded that neither federal law (15 U.S.C. § 381(a)), the Commerce Clause, nor any constitutional provision barred the tax, as Maine’s regulatory scheme served a legitimate state purpose and was applied equally to in-state and out-of-state businesses. The Court further held that Fifth Generation did not have “substantial authority” to justify waiving penalties. The Superior Court’s judgment was affirmed. View "State Tax Assessor v. Fifth Generation, Inc." on Justia Law