Justia Maine Supreme Court Opinion Summaries

Darling’s Auto Mall is a franchisee of General Motors LLC (GM) and and authorized dealer. Darling’s filed two small claims actions in district court alleging that it had been underpaid by GM for certain warranty repairs in violation of the Business Practices Between Motor Vehicle Manufacturers, Distributors and Dealers Act (Dealers Act). The district court ruled in favor of Darling’s on both small claims. GM appealed and requested a jury trial de novo. The superior court granted GM’s request. After a jury trial, the superior court entered a judgment in favor of GM. The Supreme Judicial Court affirmed, holding (1) the superior court’s decision to grant a jury trial de novo was not an appealable determination; (2) the trial court did not err in denying Darling’s motion for judgment as a matter of law; and (3) the trial court properly rejected Darling’s proposed jury instructions. View "Darling's Auto Mall v. General Motors LLC" on Justia Law

Darling’s Auto Mall is a franchisee of General Motors LLC (GM) and and authorized dealer. Darling’s filed two small claims actions in district court alleging that it had been underpaid by GM for certain warranty repairs in violation of the Business Practices Between Motor Vehicle Manufacturers, Distributors and Dealers Act (Dealers Act). The district court ruled in favor of Darling’s on both small claims. GM appealed and requested a jury trial de novo. The superior court granted GM’s request. After a jury trial, the superior court entered a judgment in favor of GM. The Supreme Judicial Court affirmed, holding (1) the superior court’s decision to grant a jury trial de novo was not an appealable determination; (2) the trial court did not err in denying Darling’s motion for judgment as a matter of law; and (3) the trial court properly rejected Darling’s proposed jury instructions. View "Darling's Auto Mall v. General Motors LLC" on Justia Law

Arthur Murdock, then a lieutenant with the Maine State Police, was injured when his cruiser was struck by another vehicle after Martin Thorne indicated that Murdock could turn in front of him into an intersection. Murdock filed a four-count complaint alleging negligence against Castigliola and Thorne and seeking uninsured motorist coverage from the Maine Department of Public Safety (DPS). The superior court granted the motions for summary judgment filed by both DPS and Thorne. Murdock appealed, and DPS cross-appealed. The Supreme Judicial Court dismissed the appeals, holding that the superior court improvidently granted Murdock’s motion to enter final judgment on Murdock’s claims against Thorne and DPS pursuant to Me. R. Civ. P. 54(b)(1). View "Murdock v. Thorne" on Justia Law

In this case, the Supreme Court considered when a municipal agency’s decision constitutes a final action subject to immediate judicial review. The owner of the Camden Harbour Inn applied to the Town of Camden for authorization to increase the number of guest rooms and parking spaces for the Inn and to reduce the number of seats at the Inn’s restaurant. The Zoning Board of Appeals (ZBA) granted a special exception permit subject to conditions and allowed the Inn to proceed to the Planning Board for site plan review. Susan Bryant, an abutter, appealed the ZBA’s decision to the superior court before site plan review could occur. The superior court affirmed the ZBA’s decision. The Supreme Court vacated the judgment of the superior court and remanded for dismissal of Bryant’s complaint, holding that, while the Town’s Zoning Ordinance expressly provided for Bryant’s appeal from the grant of the preliminary special permit, the ZBA’s decision was not a final action subject to appellate review in the courts because additional process was required by the Town’s Ordinance before a final decision on the Inn’s proposed changes is reached. View "Bryant v. Town of Camden" on Justia Law

Defendants defaulted on their mortgage, and U.S. Bank filed a complaint for foreclosure. Following the Supreme Judicial Court’s decision in Bank of America, N.A. v. Greenleaf, the Bank filed a motion to voluntarily dismiss the foreclosure action without prejudice, arguing that it could not proceed with the foreclosure because it did not have a mortgage assignment from the original lender and thus did not have standing to pursue the action. Defendants countered that the motion should be dismissed with prejudice so that they could be awarded attorney fees. The trial court granted the Bank’s motion but dismissed the case with prejudice. The court subsequently issued a correction of the record stating that the dismissal of the Bank’s action was without prejudice. The Supreme Judicial Court vacated the judgment of dismissal with prejudice and subsequent judgment of dismissal without prejudice, holding that the trial court erred in dismissing the Bank’s action with prejudice and did not have authority under the circumstances to change that outcome to a dismissal without prejudice. Remanded for the entry of judgment of dismissal without prejudice. View "U.S. Bank Nat’l Ass’n v. Curit" on Justia Law

John Dyer gave a promissory note and a mortgage on property securing the note to Countrywide Home Loans, Inc. The mortgage contained language naming Mortgage Electronic Registration Systems, Inc. (MERS) as lender’s nominee. The Bank of New York later filed a complaint for foreclosure, asserting that Dyer had stopped making payments on the note and that he owed the Bank over $1 million. During the trial, the Bank filed a motion to dismiss its complaint without prejudice on the ground that it did not have the requisite standing to pursue its claim. Dyer filed an objection requesting that any dismissal be with prejudice and that he be awarded his attorney fees and costs. The district court granted the Bank’s motion to dismiss without prejudice and declined to award additional attorney fees or costs. The Supreme Judicial Court affirmed, holding that the district court did not err in dismissing the complaint without prejudice and in declining to award Dyer his full attorney fees and costs. View "Bank of New York v. Dyer" on Justia Law

Mother and Father met in Guatemala, and their child was born there. When the child was approximately fifteen months old, Father filed a complaint in Maine to establish parental rights and responsibilities. Mother was not served in Maine and did not consent to jurisdiction in Maine, and neither Mother nor the child ever resided in Maine. Mother moved to dismiss the complaint for lack of jurisdiction, arguing that Maine lacked long-arm jurisdiction over her. The district court granted Mother's motion to dismiss, determine that Maine lacked jurisdiction pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The Supreme Judicial Court affirmed, holding that the district court properly determined that the UCCJEA governed its determination of jurisdiction in this matter. View "Seekings v. Hamm" on Justia Law

After almost five years of litigation, the probate court issued its final judgment in the formal testate proceeding concerning the estate of Mildred D. MacComb. James Richman appealed. The Supreme Judicial Court rejected Richman’s brief and his amended brief and dismissed the appeal for want of prosecution. Richman asked that the Court reconsider the rejection of his amended brief and the dismissal of his appeal. The Supreme Judicial Court denied the motion for reconsideration, as Richman failed to comply with the Maine Rules of Appellate Procedure and a direct order from the Court. View "In re Estate of MacComb" on Justia Law

Bank of America brought this foreclosure action against Marianne Gregor. Homeward Residential, Inc. was later substituted as plaintiff. The district court entered judgment for Gregor, determining that Homeward Residential had not established that it had standing to foreclose on the mortgage. In its judgment, the court stated that “[t]he parties may relitigate issues discussed herein in a future action.” The Supreme Judicial Court vacated the judgment, holding that the district court (1) correctly determined that Homeward Residential lacked standing to pursue the foreclosure claim; but (2) erred when it made findings and entered judgment for Gregor rather than dismissing the action for lack of standing. Remanded for an entry of a dismissal without prejudice. View "Homeward Residential, Inc. v. Gregor" on Justia Law

The trial court entered summary judgment in favor of Defendants on Plaintiff’s claims for wrongful use of civil proceedings and abuse of process. Plaintiff appealed, arguing that the trial court erred in concluding that Plaintiff failed to establish a prima facie case for each element of both causes of action. The Supreme Judicial Court affirmed but noted that the trial court would have been well within its discretion to have granted a summary judgment in favor of Defendant based solely on Plaintiff’s failure to comply with the requirements of Me. R. Civ. P. 56(h), or to have denied summary judgment altogether based on the manner in which both parties availed themselves of the summary judgment process. View "First Tracks Invs., LLC v. Murray, Plumb & Murray" on Justia Law