Justia Maine Supreme Court Opinion Summaries

After credit card fraud was discovered on vacations that Beth Rogers, a travel agent, had booked, Plaintiffs, two families, each filed a complaint against Mark Travel Corporation alleging breach of contract, economic duress, and violations of the Maine Unfair Trade Practices Act. The business and consumer docket granted summary judgment for Mark Travel. The Supreme Judicial Court affirmed, holding that the trial court did not err in determining that Plaintiffs’ claims against Mark Travel failed as a matter of law because Rogers was not an agent of Mark Travel, and Mark Travel did not authorize Rogers to act on its behalf, ratify Rogers’s fraudulent conduct, or hold Rogers out as its agent. View "Remmes v. Mark Travel Corp." on Justia Law

In anticipation of renting an apartment from Sheldon Ashby, Jennifer Roussel gave Ashby a security deposit. Roussel never moved into the apartment and sought the return of her security deposit. When Ashby did not respond to Roussel’s demand for a refund, Roussel filed a complaint against Ashby. The superior court entered default against Ashby and entered judgment for Roussel in the amount of $24,628. Roussel appealed, and Ashby cross-appealed the denial of his motion to set aside the default. The Supreme Court affirmed, holding that the trial court did not err in (1) declining to aware punitive damages to Roussel; (2) denying Roussel’s motion to amend the judgment by awarding additional attorney fees; and (3) denying Ashby’s motion to set aside the default. View "Roussel v. Ashby" on Justia Law

James Stanley, Barbara Stanley and Northeast Marine Services, Inc. (collectively, “Stanley”) were parties to a binding arbitration with Michael Liberty and five corporations under his control (“the Liberty corporate entities”) regarding contractual and fiduciary disputes arising from Stanley’s tenure as an officer and director of the Liberty corporate entities. Many of Stanley’s claims were rejected, but the three main issues relevant to this appeal were decided in favor of Stanley. The business and consumer docket affirmed the arbitration award in full. The Supreme Court affirmed, holding (1) in challenging the arbitrator’s findings that Stanley had not engaged in a breach of fiduciary duty regarding transactions involving the Liberty corporate corporate entities, Liberty and the Liberty corporate entities asked the court to review fact-findings by the arbitrator, and such findings were not reviewable; (2) Liberty and the Liberty corporate entities did not demonstrate that the arbitrator exceeded his broad authority in interpreting the retirement contract that generated this litigation; and (3) the arbitrator did not exceed his authority by deciding to pierce the corporate veil and make Liberty personally liable for obligations of his closely-controlled corporations. View "Stanley v. Liberty" on Justia Law

Plaintiff, a construction company, filed a five-count complaint in superior court against Defendants, alleging breach of contract, quantum meruit, unjust enrichment, and violation of the Prompt Payment Act. In the fifth count of the complaint, Plaintiff sought enforcement of a mechanic’s lien it recorded against Defendants’ property. Plaintiff then moved for summary judgment on its claims for breach of contract, violation of the Prompt Payment Act, and enforcement of the mechanic’s lien. The superior court granted summary judgment for Plaintiff on those three counts but made no mention of Plaintiff’s quantum meruit or unjust enrichment claims. Defendants appealed. The Supreme Court dismissed the appeal as interlocutory, as there was no final judgment on any of Plaintiff’s causes of action where two of Plaintiff’s claims were still pending. View "Warren Constr. Group, LLC v. Reis" on Justia Law

Dozens of suits were filed against Irving Oil Limited (IOL) alleging environmental contamination by methyl tertiary butyl ether (MTBE) occurring from 1979 to the present. At the time of this opinion, all of the MTBE suits against IOL had been settled. In 2009, IOL filed a complaint asking the superior court to declare that ACE INA Insurance (ACE) had a duty to defend and indemnify in the MTBE suits. The superior court granted IOL’s motion for summary judgment in part and denied it in part, concluding that it could not declare that IOL was entitled a judgment on the duty-to-defend count as a matter of law. IOL appealed. The Supreme Court dismissed IOL’s appeal and ACE’s cross-appeal, holding that although a decision that an insurer does not have a duty to defend its insured is ordinarily immediately appealable under the death knell exception to the final judgment rule, the exception did not apply in this case because there were no MTBE cases pending against IOL.View "Irving Oil Ltd. et al. v. ACE INA Ins." on Justia Law

Philip Barter hired Philip Tobin to produce a book encompassing Barter’s artistic works. The parties subsequently entered into a written agreement providing that Tobin would write the text for the book and setting forth the financial arrangements. Tobin drafted a manuscript of the book and gave Barter a draft of the manuscript, but Barter did not respond. Thereafter, Tobin filed a complaint alleging that Barter had breached the parties’ contract. The jury returned a verdict in favor of Tobin. The next day, the trial court granted Barter’s motion for a judgment as a matter of law, concluding that Tobin had failed to present sufficient evidence that the parties had a meeting of the minds necessary to form a legal contract. The Supreme Court reversed and remanded with directions to reinstate the jury’s verdict in favor of Tobin, holding (1) the trial court erred in issuing its judgment in favor of Barter as a matter of law; and (2) a jury rationally could have found that Barter had materially breached the contract by failing to respond to Tobin.View "Tobin v. Barter" on Justia Law

Edwina Jones rented a residence that she vacated in 2010. Because Jones did not replace heating oil in the residence’s oil tank at the end of her tenancy under the terms of the lease, Cost Management, Inc., the landlord, told Jones that it would return to Jones the $1,500 deposit minus $448, the cost of filling the oil tank. Jones filed a complaint against Cost Management asserting that she was entitled to $1,500, plus statutory double damages, attorney fees, interest and costs. Cost Management counterclaimed for the $448 it paid to fill the tank. The district court found in Jones’s favor on her complaint, found in favor of Cost Management on its counterclaim, and denied Jones’s claims for costs, double damages, and attorney fees under the wrongful-retention statute. The Supreme Court affirmed, holding (1) the district court correctly found that Jones was entitled to receive $1,052 from Cost Management; and (2) because Cost Management overcame the presumption that it wrongfully withheld Jones’s security deposit, the district court did not err by not awarding court costs, double damages, and attorney fees.View "Jones v. Cost Mgmt., Inc." on Justia Law

When Michael Lewis was sixteen years old, he was involved in a fatal car accident. At the time, Michael was driving a Ford pickup truck he had allegedly purchased from William Dodge. The other driver’s insurer paid Michael’s estate (Estate) its policy limit for liability. Michael’s mother, Angela, was insured by Concord General Mutual Insurance Company (Concord) at the time of the accident, and Michael’s father, David, was insured by Allstate Fire and Casualty Insurance Company (Allstate). The Concord and Allstate policies provided uninsured motorist (UM) benefits, as did Dodge’s policy with Property and Casualty Insurance Company of Hartford (Hartford). The Estate sought UM benefits from all three insurance companies. Each denied coverage, and the Estate filed suit against each company. The Superior court entered summary judgment in favor of Defendants. The Supreme Court vacated the judgment, holding that a genuine issue of material fact existed as to whether, pursuant to the agreement between Michael and Dodge, a final sale on the truck had been completed by the time of the accident. Remanded. View "Estate of Lewis v. Concord Gen. Mut. Ins. Co." on Justia Law

After Harold Forest Snow died, Linda Moulton, as personal representative, filed a civil action against Susan Snow, alleging that one of the transfers identified in Harold’s codicil was an improvident transfer and a product of undue influence. During discovery, the parties’ attorneys announced that they had settled the case. Neither side, however, would agree to sign the other’s proposed settlement documents. Linda subsequently filed a motion to enforce the settlement agreement. The probate court granted Linda’s motion to enforce, finding that the record contained an “unequivocal stipulation by the parties’ attorneys that the matter was settled” and that the material terms of the agreement were clearly defined in the transcript. The Supreme Court affirmed, holding (1) there was ample evidence that the parties intended to enter into an enforceable settlement agreement and that the terms placed on the record reflected all of the material terms of the contract; and (2) the probate court did not abuse its discretion in granting the motion to enforce the settlement agreement without holding a trial or an evidentiary hearing. View "In re Estate of Snow" on Justia Law

Defendant entered into a land installment contract that established the terms of a transfer from Plaintiffs to Defendant of a parcel of land. Defendant failed to make the payments required by the contract, and Plaintiffs commenced this action. Defendant argued that because the contract did not comply with 33 Me. Rev. Stat. 482(1) Plaintiffs were barred from obtaining relief. The district court entered a judgment of foreclosure against Defendant and ordered a writ of possession in favor of Plaintiffs, concluding that, even if the contract failed to comply with section 482(1), Plaintiffs would have had could obtain possession of the property through the forcible entry and detainer process. The Supreme Court affirmed, holding (1) the contract was enforceable because it was in substantial compliance with section 482(1); and (2) 14 Me. Rev. Stat. 6203-F does not require a court to order a public sale of property when ordering a foreclosure on a land installment contract. View "Thurston v. Galvin" on Justia Law