Justia Maine Supreme Court Opinion Summaries

Articles Posted in Business Law
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John and Paul Pelletier formed St. Sauveur Development in the 1970s and transferred title of several jointly-owned properties to the corporation. In 2002, an appraiser appraised the corporation's property holdings. After the appraisal, the brothers agreed to divide the properties and how they would be divided, with the understanding that John would make a cash payment to Paul to equalize the division. In 2004, John began making payments to Paul. In 2005, the brothers received an analysis from Paul's accountant that they agreed on the actual amount of Paul's payment and to the payment terms, including the interest rate. Paul subsequently filed a complaint for dissolution and other relief. The business and consumer docket determined and divided John's and Paul's interests in St. Sauveur, concluding that the parties had entered into an enforceable agreement in 2002. The Supreme Court vacated in part, holding (1) the agreement regarding interest was reached in 2005, and therefore, the court's determination that interest should accrue from the date of the 2002 appraisal was error; and (2) the court did not err in failing to find that a check from St. Sauveur that Paul negotiated in 2009 gave rise to an accord and satisfaction. Remanded. View "Pelletier v. Pelletier" on Justia Law

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After Valley Firewood and Tree Farm (collectively, Valley) terminated its firewood business, Gary Voisine, on behalf of Valley, filed a three-count shareholder's derivative action against Valley and Robert Berube, a shareholder and president of Valley. After a bench trial, the superior court found Berube breached his duty to act in good faith toward Valley and awarded damages to Valley in the amount of $1,500,000, with half that sum, $750,000 plus interest and costs, to be paid over to Voisine. At issue on appeal was whether Valley itself was damaged and suffered losses as a result of Berube's conduct and whether Voisine had standing to bring the derivative action on Valley's behalf. The Supreme Court vacated the judgment of the superior court, holding that Voisine lacked standing to bring a shareholder's derivative action on behalf of Valley and was not entitled to damages as a matter of law because Voisine participated in the division of assets of Valley, received the benefits of that distribution, and created a corporation to sell firewood formerly sold by Valley that was intended to replace Valley. View "Voisine v. Berube" on Justia Law

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Employer, an employment agency, hired Employee and assigned him to work at a facility owned by a client company (Client). Employer paid Employee's salary, and Client paid Employer a fee for his services. Employee was injured while working at the Client plant, after which Client ended Employee's assignment at its facility. Employee filed petitions to remedy discrimination against Employer and Client. A workers' compensation board hearing officer denied the petitions to remedy discrimination against Employer and Client. Employee appealed, contending that the hearing officer erred by denying the petition against Client on the ground that Employee was not in an employer-employee relationship with Client. The Supreme Court affirmed, holding (1) the hearing officer did not misconceive the legal standard when focusing on whether a contract for hire existed between Employee and Client; (2) the hearing officer did not err in concluding that Employee had a contract for hire only with Employer; and (3) therefore, Employee did not have a right of action for discrimination pursuant to 39-A Me. Rev. Stat. 353 against Client. View "Doughty v. Work Opportunities Unlimited" on Justia Law

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The State filed an antitrust enforcement action against four MaineHealth entities based on the proposed acquisition by MaineHealth of two major cardiology practices. The matter was transferred to the business and consumer docket. Central Maine Medical Center (CMMC) moved to intervene in the proceeding, arguing that it had an interest in the case as a principal competitor in cardiovascular surgery of one of MaineHealth's hospitals. The lower court denied CMMC's motion. The Supreme Court affirmed the denial of CMMC's motion, holding (1) because CMMC made no evidentiary showing of bad faith, collusion, or other malfeasance on the part of the government, and did not demonstrate that the disposition of the antitrust action would impair its ability to protect its interests through independent litigation, intervention of right was properly denied; and (2) the lower court did not err in denying permissive intervention after determining that joining the private cause of action to the State's enforcement claim would unduly burden the proceedings and supplying an alternative method for CMMC to participate in the action by providing oral comments and written submissions to the court. View "State v. MaineHealth" on Justia Law

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The Witham Family Partnership challenged two decisions of the Town of Bar Harbor's Zoning Board of Appeals (Board) in connection with North South Corporation's application to construct a hotel. The Partnership attended two public hearings before the Board on North South's appeal of the planning board's denial of its application. The Board subsequently reversed the planning board's denial. The Partnership also filed its own appeal challenging the portion of the planning board's decision finding that North South's proposed project conformed to certain criteria for obtaining a building permit. The Board affirmed the planning board's decision. The Partnership then filed a Me. R. Civ. P. 80B complaint challenging the Board's decisions in both North South's appeal and in the Partnership's appeal. The superior court dismissed the complaint on grounds that the Partnership lacked standing. The Supreme Court reversed, holding that the Partnership had standing to challenge the Board's decision in both appeals in a Rule 80B review of those decisions. View "Witham Family Ltd. P'ship v. Town of Bar Harbor " on Justia Law

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The Town of Lebanon filed a land use complaint against East Lebanon Auto Sales (the LLC) and Linda Corbin, the sole member of the LLC, alleging that property owned by the LLC in Lebanon constituted an illegal automobile graveyard and illegal junkyard and that the property had an improper subsurface wastewater system. The district court issued a judgment against the LLC and Corbin in the amount of $2000 plus attorney fees. On appeal, the Supreme Court (1) vacated the decision of the district court as to Corbin individually, concluding that the record contained no evidence that suggested that Corbin abused the privilege of incorporating or that an unjust result would occur if only the LLC were held liable on the Town's complaint; and (2) affirmed the judgment of the district court in all other respects, finding the remaining issues raised by the LLC to be without merit. View "Town of Lebanon v. East Lebanon Auto Sales, L.L.C." on Justia Law