Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the summary judgment entered by the superior court in favor of Defendant on Plaintiff’s complaint asserting that Defendant was negligent and had caused Plaintiff economic harm, holding that claim preclusion cannot operate to bar a subsequent suit brought in district or superior court by a person who was not an actual party in a previous small claims action.A third party driving a vehicle owned by Plaintiff was involved in a collision with a vehicle driven by Defendant. In a small claims matter, Defendant sued the third party, and the district court found the third party was negligent. Plaintiff then brought this action against Defendant. The superior court applied the doctrine of res judicata to the earlier small claims judgment and determined that the earlier judgment conclusively resolved the issue of which driver was at fault. The Supreme Court vacated the judgment, holding that, because of the unique limitations of small claims procedure, claim preclusion did not bar this suit by a person who was, at most, in privity with the defendant in the small claims case. View "Ring v. Leighton" on Justia Law

In this dispute over the location of the boundary between the land of Appellees and the land of Appellants, the Supreme Judicial Court affirmed the judgment of the superior court declaring the location of that boundary line, holding that the superior court did not err or abuse its discretion.On appeal, Appellants generally challenged the discretionary decisions made by the trial court in its management of the proceeding. The Supreme Judicial Court denied the challenges, holding that, contrary to Appellants’ contentions, the trial court did not err or abuse its discretion either in its case management orders or in its findings and conclusions. View "Gammon v. Boggs" on Justia Law

The Supreme Judicial Court dismissed this appeal challenging the promulgation of a final rule by the Public Utilities Commission, holding that this Court does not have original jurisdiction over appeals from administrative rulemaking proceedings.Appellants, including the Conservation Law Foundation, the Industrial Energy Consumers’ Group, ReVision Energy, LLC, and the Natural Resources Council of Maine, argued, among other things, that, in promulgating the rule at issue, the Commission violated several provisions of the Maine Administrative Procedure Act, that the rule violated statutory ban on exit fees, and that the rule unjustly discriminated. The Commission argued that Me. Rev. Stat. 35-A, 1320 does not authorize appeals to the Law Court when the Commission acts pursuant to its rulemaking authority. The Supreme Judicial Court agreed, holding that any appeal from Commission rulemaking proceedings must be brought originally in the Superior Court. View "Conservation Law Foundation v. Public Utilities Commission" on Justia Law

In this interlocutory appeal, the Supreme Judicial Court remanded the matter without reaching the merits of the appeal, holding that the discovery order challenged on appeal was now a nullity and did not govern future proceedings in this case and that no exception to the final judgment applied.Appellants appealed from an order of the superior court granting Appellee’s motion to compel them to produce in discovery certain patient medical records that the court found to relevant to Appellees' notice of claim asserting medical negligence. The Supreme Judicial Court held (1) given the unusual procedural posture presented in this case, the discovery order was a nullity without legal force or effect and did not govern future proceedings in this case; and (2) no exception to the final judgment rule applied that would require the Court to reach the merits of the parties’ arguments below. View "McCain v. Vanadia" on Justia Law

The “prisoner mailbox rule” applies when a prisoner is forced to rely on the Department of Corrections to ensure that his Me. R. Civ. P. 80C petition is filed, that prisoner places the petition into the control of the Department, and the Department fails timely to deliver the petition to the clerk of court.Petitioner signed a petition pursuant to Me. Rev. Stat. 5, 11002 for judicial review of a Department decision finding that he had committed a disciplinary infraction. The State moved to dismiss the petition for failure to state a claim, arguing that because the clerk of court received Petitioner’s petition one day outside of the thirty-day statutory window, the superior court lacked jurisdiction over the matter. Petitioner urged the superior court to apply the prison mailbox rule, whereby the court would consider the petition filed on the date Petitioner deposited it with prison officials for forwarding to the clerk of court rather than the day it was received by the clerk of court. The court granted the State’s motion to dismiss. After setting forth the circumstances above under which the prisoner mailbox rule applies the Supreme Judicial Court adopted the prison mailbox rule for any unrepresented prisoner under the circumstances of this case, vacated the judgment, and remanded to the superior court for reinstatement of the Rule 80C petition. View "Martin v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed a summary judgment entered in the Business and Consumer Docket in favor of Copay Italia S.p.A. on Puritan Medical Products Company’s claim that Copay violated Maine’s Actions for Bad Faith Assertion of Patent Infringement statute, Me. Rev. Stat. 14, 8701-8702, holding that Puritan’s claim was preempted by federal patent law.Although the lower court granted summary judgment for Copan after finding no genuine issues of material fact and determining that Copay was entitled to judgment as a matter of law, Copan filed a cross-appeal challenging the court’s conclusion that Puritan’s claim was not preempted by federal law. The Supreme Judicial Court affirmed, holding (1) in its preemption analysis, the trial court conflated the test for federal preemption with the test for federal jurisdiction; and (2) federal patent law preempted Puritan’s state law claim, and therefore, summary judgment in favor of Copay was properly granted on that basis. View "Puritan Medical Products Co. v. Copan Italia S.p.A." on Justia Law

The Supreme Judicial Court dismissed this interlocutory appeal brought by Defendants challenging the superior court’s denial of their motion to seal or strike, holding that Defendants did not demonstrate the irreparable harm necessary for appellate review of the court’s interlocutory order.Plaintiff, the respondent in an attorney discipline proceeding, filed a complaint against Judge Marian Woodman and Judge Nancy Carlson based on their actions and involvement in the disciplinary proceeding. Defendants filed motions to dismiss the complaint and sought imposition of sanctions. After Plaintiff filed a response to the motions the judges filed a motion to seal or strike certain paragraphs of Plaintiff’s response, in which Plaintiff made assertions about the judges and a family member of one of them. The superior court denied the motion. The judges appealed. The Supreme Judicial Court dismissed the appeal, holding that the appeal did not fall within an exception to the final judgment rule. View "Carey v. Maine Board of Overseers of the Bar" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing Petitioner’s complaint seeking review of a disciplinary decision of the Department of Corrections. In dismissing the petition, the superior court entered sua sponte a decision stating that the case was dismissed for lack of jurisdiction. The record was otherwise devoid of any indication of the basis on which the court concluded that it lacked jurisdiction. The Supreme Judicial Court held that no jurisdictional defect was apparent from the record and remanded the matter to the superior court for the court to act on Petitioner’s application to proceed without payment of fees. View "Anctil v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed the judgment of divorce, defaulting Husband, holding that the district court did not err in determining that service by publication was adequate.When Wife filed a complaint for protection from abuse against Husband, Husband fled to Florida in order to evade service of process. Two months later, Wife prepared a complaint for divorce from Husband, but neither she nor the sheriff’s office was able to find him to serve him with the divorce complaint. The district court granted a motion for service of the divorce complaint by alternate means, allowing Wife to effect service by publishing notice of the complaint in the Lewiston Sun Journal. When Father failed to appear at the divorce hearing, the district court entered a judgment of divorce defaulting Husband. The Supreme Judicial Court affirmed, holding (1) Me. R. Civ. P. 4 did not impose a requirement that a copy of the order granting alternate service be personally delivered to Husband; and (2) the district court’s decision not to require Wife to send an email to Husband’s possible email address or notify Husband’s attorney of the order for service by publication did not result in a failure of due process. View "Schulz v. Doeppe" on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the district court denying Father’s Me. R. Civ. P. 60(b) motion for relief from judgment after the court granted Mother’s motion to modify a parental rights and responsibilities order regarding the parties’ son. On appeal, Father argued that the court erred in denying his motion because (1) after another state assumed jurisdiction over the child custody matter, Maine necessarily lost jurisdiction over that matter; and (2) the court erred by not allowing him to present facts and legal arguments to the court before a decision on jurisdiction was made. The Supreme Judicial Court disagreed, holding (1) Maine maintained exclusive, continuing jurisdiction over the child custody matter pursuant to Me. Rev. Stat. 19-A, 1746(1); and (2) the court acted within the confines of section 1740(2), and because Father on two occasions had already presented facts and legal arguments regarding jurisdiction, the court did not abuse its discretion in denying Father a third opportunity to address the matter. View "Fitzpatrick v. McCrary" on Justia Law