Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated in part and affirmed in part the lower court's judgment in favor of Plaintiffs and against Compass Harbor Village Condominium Association and Compass Harbor Village, LLC (collectively, Compass Harbor), holding that the court erred in ordering specific performance and entering judgment for Plaintiffs on the claim brought pursuant to the Maine Unfair Trade Practices Act (UTPA), Me. Rev. Stat. 5, 205-A to 2014.Plaintiffs brought suit alleging that Compass Harbor's actions with respect to maintenance and governance of the Association caused their units to lose value. The lower court found that Compass Harbor breached the contracts between it and Plaintiffs, the LLC violated its fiduciary duties to Plaintiffs, and Compass Harbor violated section 207 of the UTPA. The court awarded damages to Plaintiffs and entered an order of specific performance requiring Compass Harbor to abide by its contractual and fiduciary duties in the future. The Supreme Judicial Court vacated the judgment in part, holding (1) the UTPA did not apply in this case; (2) the court did not clearly err in calculating damages; and (3) the court went beyond its discretion in entering an order that would involve the court in continuous supervision of Compass Harbor's performance over an indefinite period. View "Brown v. Compass Harbor Village Condominium Ass'n" on Justia Law

In this dispute over a purported royalty fee, the Supreme Judicial Court vacated the superior court's order granting partial summary judgment in favor of InfoBridge, LLC on InfoBridge's claim for breach of contract, holding that the contract's royalty provision was ambiguous.Chimani and InfoBridge entered into a contract under which InfoBridge would create a software program. For this work, Chimani was to pay InfoBridge scheduled payments. The contract also contained a royalty provision requiring Chimani to pay InfoBridge royalties. InfoBridge later filed a complaint against Chimani alleging, inter alia breach of contract. InfoBridge then moved for partial summary judgment on its breach of contract claim, arguing that the royalty provision unambiguously required Chimani to pay InfoBridge 14.5 percent of Chimani's net revenue from the program, up to a total royalty fee of $150,000. The court granted the motion for summary judgment and denied Chimani's cross-motion for summary judgment on its equitable estoppel affirmative defense on the grounds that Chimani waived the equitable estoppel issue. The Supreme Court affirmed in part and vacated in part the judgment below, holding (1) Chimani waived its equitable estoppel defense; but (2) the royalty provision was ambiguous, and the summary judgment record did not permit a determination of its meaning as a matter of law. View "InfoBridge, LLC v. Chimani, Inc." on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court in favor of Defendants following a bench trial on Plaintiffs' claims against Defendants stemming from Plaintiffs' purchase of Defendants' house, holding that the trial court's factual findings were supported by the evidence and that the court did not err in deciding in favor Defendants.Defendants entered into a purchase and sale agreement with Plaintiffs to sell Defendants' home. After Plaintiffs discovered a number of deficiencies in the house they filed a complaint alleging counts arising from the house's sale and defects. The trial court granted judgment in favor of Defendants. The Supreme Judicial Court affirmed, holding that the trial court's explicit findings were comprehensive, detailed, and adequately supported by record evidence. View "Wuestenberg v. Rancourt" on Justia Law

In this appeal arising from a set of commercial construction projects the Supreme Judicial Court affirmed the judgment in favor of Fortney & Weygant, Inc. (F&W) on the counterclaims filed by Lewiston DMEP IX, LLC, et al. (collectively, GBT) for liquidated damages, affirmed in part as to the prompt payment remedies allowed to F&W, and vacated the portion of the judgment awarding attorney fees and costs to F&W pursuant to the terms of the parties' contract.The trial court determined that, in addition to damages for breach of contract, F&W was entitled to remedies, including attorney fees pursuant to Maine's prompt payment statutes, that F&W was entitled to attorney fees pursuant to the terms of the parties' contract, and that GBT was estopped from seeking to enforce a contractual right to liquidated damages against F&W. The Supreme Judicial Court held that the trial court (1) did not erroneously conclude that GBT was equitably estopped from recovering liquidated damages against F&W; (2) properly awarded F&W prompt payment remedies except to the extent that the remedy failed to account for the value of GBT's liquidated damages claims that GBT withheld in good faith; and (3) erred when it concluded that the contract contemplated an award of attorney fees outside the context of arbitration. View "Fortney & Weygandt, Inc. v. Lewiston DMEP IX, LLC" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing Appellant's compliant alleging revocation of acceptance and breach of warranty as time-barred, holding that the court relied upon facts contained in documents that exceeded the scope of the facts that may be considered by the court in the context of a motion to dismiss.Appellant brought this action alleging claims with respect to a bicycle frame that he purchased that was manufactured by Independent Fabrication, Inc. The district court dismissed the complaint as barred by the four-year statute of limitations set forth in Me. Rev. Stat. 11, 2-725. The Supreme Judicial Court vacated the order of dismissal on procedural grounds and remanded for further proceedings, holding that the court's consideration of matters outside the pleadings in granting Independent's motion to dismiss was in error. View "Greif v. Independent Fabrication, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on Plaintiff's claims alleging age discrimination, retaliation, breach of contract, and various other torts, holding that there was no error or abuse of discretion in the superior court's handling of Plaintiff's requested accommodations.On appeal, Plaintiff argued that the trial court abused its discretion by not, sua sponte, granting him accommodations, appointing him a guardian ad litem, or ordering that his mental health be evaluated. The Supreme Judicial Court disagreed, holding (1) the court did not err by granting summary judgment in favor of Defendants on all of Plaintiff's claims; and (2) the court properly handled Plaintiff's request for accommodations. View "Gallagher v. Penobscot Community Healthcare" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Appellants' motions for judgment as a matter of law and a new trial following a jury verdict in favor of Appellee on his claims for breach of contract, breach of fiduciary duty, and fraudulent misrepresentation, holding that the superior court did not err.Specifically, the Court held that the superior court did not err by (1) allowing Appellee to proceed on a claim of fraudulent misrepresentation based upon allegation that Appellants did not intend to perform their obligations under the contract at the time it was executed; (2) failing to give a requested jury instruction; and (3) allowing Appellee to proceed on a claim for breach of fiduciary duty when the parties' relationship was governed by a limited liability company operating agreement. View "Cianchette v. Cianchette" on Justia Law

In this appeal involving a dispute over payment for the construction of a traditional timber frame home, the Supreme Judicial Court affirmed the judgment of the superior court calculating the damages recoverable under the Unfair Trade Practice Act (UTPA) stemming from Contractor’s violation of the Home Construction Contracts Act (HCCA), holding that, the superior court did not err in its judgment.Contractor brought this action seeking to be paid for his unpaid labor. The superior court concluded (1) Contractor was entitled to the money he had already received from Homeowners under the theory of quantum meruit; (2) Homeowners did not meet their burden of proof as to their counterclaims; and (3) Contractor violated the HCCA by failing to furnish a written contract, which was prima facie evidence of a UTPA violation. The Supreme Judicial Court affirmed, holding (1) while the parties did not sign a contract in this case, the superior court’s application of quantum meruit was appropriate; (2) the superior court did not err in concluding that Homeowners failed to prove their counterclaims; (3) Homeowners were not entitled to additional damages under the UTPA; and (4) the attorneys fees award in this case was sufficient. View "Sweet v. Breivogel" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming the judgment of the district court in favor of Appellee, Appellant’s landlord, holding that Appellant’s violation of his lease in three ways that were independent from his possession of marijuana justified Appellee’s termination of the lease.Appellee issued Appellant a notice that it was terminating the parties’ lease, stating that Appellant’s use and possession of marijuana, as well as some of Appellant’s other activities, violated the terms of the parties’ lease. Appellee then filed an forcible entry and detainer complaint, and the district court entered judgment granting possession of the apartment to Appellant. Appellant appealed, arguing that because he had a certificate to use marijuana for medical purposes, Appellee and the district court were required to reasonably accommodate his possession and use of marijuana. The Supreme Judicial Court affirmed, holding that Appellant’s violations of his lease that were independent from his possession of marijuana, standing alone, justified Appellee’s termination of the lease. View "Sherwood Associates LP v. Jackson" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment to Defendant, PropertyInfo Corporation, Inc., on York County’s complaint alleging breach of contract and unjust enrichment, holding that the court did not err in its determination that York County’s claims were barred by the statute of limitations.York County’s action was based on PropertyInfo’s failure to digitize and make accessible all documents filed with the York County Registry of Deeds between 1940 and 1965. The superior court entered a summary judgment in favor of PropertyInfo, concluding that the statute of limitations had expired on each of York County’s claims. The Supreme Judicial Court affirmed, holding that the superior court properly entered summary judgment based on the expiration of the statute of limitations on each of the claims. View "York County v. PropertyInfo Corp., Inc." on Justia Law