Justia Maine Supreme Court Opinion Summaries

Plaintiff entered into a commission agreement with Company in 2002 in which Company agreed to pay Plaintiff a commission when Company sold its products to contacts that Plaintiff introduced to Company. Starting in 2004, Company began paying Plaintiff commissions for its sales to a certain contact (Avaya). Company terminated the agreement on the day that Plaintiff served it with a complaint claiming that Company owed him commissions on sales it made to another company. Company continued to sell to Avaya after terminating the agreement but did not pay Plaintiff any commissions on those sales. Plaintiff subsequently amended his complaint, and the case was tried to a jury on the issue of whether Plaintiff was due commissions resulting from Company's post-termination sales to Avaya. The trial court entered judgment for Company. The Supreme Court vacated the judgment of the trial court and remanded for entry of a judgment in favor of Plaintiff, holding (1) the commission agreement unambiguously required Company to pay commissions to Plaintiff on sales it made to Avaya after Company unilaterally terminated the agreement; and (2) therefore, Defendant was entitled to judgment as a matter of law on his breach of contract claim. View "McDonald v. Scitec, Inc." on Justia Law

Defendants installed video surveillance cameras at the entrance to an easement crossing their property. Members of a subdivision who benefitted from the easement (Plaintiffs) filed an action for a declaratory judgment and to enjoin Defendants from obstructing their easement rights. Plaintiffs relied on a 2006 settlement to support their position that Defendants were prohibited from installing the cameras. The trial court concluded that Defendants' video surveillance cameras constituted an unreasonable interference with the easement. The Supreme Court vacated the judgment of the superior court, holding (1) the 2006 settlement was relevant evidence to the reasonableness of the cameras, although it was not binding as between the parties to this suit, and the trial court did not err by considering that agreement because its terms provided evidence of the need for injunctive relief; and (2) the placement of the video cameras at issue here did not unreasonably interfere with the access easement benefitting Plaintiffs, nor did the cameras violate the non-disturbance clause in the settlement. Remanded for entry of judgment in favor of Defendants on the video camera issue. View "Flaherty v. Muther" on Justia Law

Plaintiff began working for Defendant as a salesperson in 2005. Defendant resigned from his employment in 2010 and signed a separation agreement before his departure. Defendant initially paid Plaintiff pursuant to the separation agreement but then claimed it had paid Plaintiff more than it agreed to and stopped payment on two of the checks it had issued. Plaintiff filed a complaint against Defendant for breach of contract, breach of quasi-contract, and unjust enrichment. A federal jury found that Defendant had breached its separation agreement with Plaintiff and that Plaintiff was entitled to $70,331 in quantum meruit damages from Defendant. After the jury verdict, Plaintiff moved the federal court to conclude that the the quantum meruit damages were "wages" within the meaning of 26 Me. Rev. Stat. 626. The federal court then certified a question to the Maine Supreme Court, which answered by holding (1) whether a quantum meruit recovery activates the penalty provision of section 626 depends on the services rendered; (2) if the services rendered are of the type for which an employee would have been due wages, then application of section 626 to a recovery in quantum meruit is appropriate; and (3) if not, section 626 would not apply. View "Dinan v. Alpha Networks Inc." on Justia Law

Plaintiff purchased title insurance for a condominium unit she had recently purchased. Plaintiff's neighbor subsequently initiated a lawsuit against Plaintiff alleging that Plaintiff's property was subject to a view easement. Plaintiff tendered the complaint to her title insurance company (Insurer) requesting a defense pursuant to her title insurance policy. Commonwealth denied Plaintiff's request based on certain exclusions in the policy. Plaintiff sued Insurer alleging a breach of contract and requesting a declaratory judgment that Insurer had a duty to defend Plaintiff against her neighbor's complaint. The superior court granted Insurer's motion for summary judgment, finding that the policy specifically excluded the view easement from coverage. The Supreme Court vacated the judgment, holding that due to the broad nature of the duty to defend and the law's requirement that insurance-policy interpretation be focused on the insured, Insurer had a duty to defend Plaintiff in the underlying litigation. View "Cox v. Commonwealth Land Title Ins. Co." on Justia Law

Prime Motor Cars sold Seacoast RV, Inc. a car. The car had modifications that voided the manufacturer's warranty and caused mechanical problems that may not have been apparent when the car was sold because the "check engine" light was covered with opaque tape. Seacoast filed a complaint against Prime, alleging breach of contract, breach of warranty, fraud, violation of the Maine Unfair Trade Practices Act (UTPA), and punitive damages. The district court granted Prime's motion for judgment as a matter of law on the UTPA and punitive damages claims. The court then concluded that Prime's conduct constituted breach of contract and breach of warranty, but found against Seacoast on the fraud claim. The court rescinded the contract and ordered Prime to refund Seacoast and Seacoast to return the vehicle to Prime. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Seacoast RV, Inc. v. Sawdran, LLC" on Justia Law

First Franklin Financial Corporation and Jason Gardner attended foreclosure mediation. The parties disputed the outcome of the mediation. Gardner argued that the parties reached a binding agreement requiring First Franklin to offer a trial loan modification plan to Gardner and subsequently filed a motion for sanctions. The district court granted the motion and ordered First Franklin to pay monetary sanctions and to enter into a loan modification with Gardner on the terms agreed upon by the parties at foreclosure mediation. First Franklin filed an interlocutory appeal. The Supreme Court granted the appeal and held that the motion court did not err (1) in finding that Gardner and First Franklin entered into a binding agreement requiring First Franklin to offer the loan modification to Gardner; and (2) in finding that First Franklin did not mediate in good faith and in granting Gardner's motion for sanctions. View "First Franklin Fin. Corp. v. Gardner" on Justia Law

This was the second appeal from a judgment of the superior court finding that Annabelle Robbins had breached implied covenants in her deed when she sold land to David and Vickie Lloyd. On appeal, Robbins' estate argued that the trial court erred in (1) finding that the six-year statute of limitations had not expired, (2) finding that the neighboring landowners never possessed or occupied the disputed land and that it misquoted the neighbor's testimony in its decision, and (3) awarding damages in the amount agreed to by the parties in a stipulated judgment because the court vacated that judgment in 2010. The Supreme Court affirmed, holding (1) the trial court properly found the statute of limitations had not expired at the time when the Lloyds filed their complaint alleging Robbins's breach; (2) the court's misstatement in its decision was harmless; and (3) the court did not abuse its discretion in awarding damages because the Estate failed to present any evidence that the stipulated damages were manifestly unjust and should be set aside. View "Lloyd v. Robbins" on Justia Law

This appeal arose from a motor vehicle collision involving Roger Linton and James Carey that resulted in Carey's death. At the time of the collision, Linton was driving a truck owned by Jonathan Jennings, for whom Linton worked as an independent contractor. Jennings's insurer, State Farm, filed a declaratory judgment action against Carey's Estate and Linton to determine whether it was responsible for liability coverage and obligated to defend and indemnify Linton for claims arising from the collision. The superior court entered a judgment in favor of State Farm, concluding that Linton was not an insured covered by Jennings's policy because his use of the truck was not within the scope of Jennings's consent. At issue on appeal was whether the superior court erred in its application of the minor deviation rule in determining that Linton's use of the truck exceeded the scope of Jennings's consent. The Supreme Court vacated the judgment, clarified the applicable burdens associated with the minor deviation rule, and remanded for the superior court to apply the minor deviation rule as clarified. View "State Farm Mut. Auto. Ins. Co. v. Estate of Carey" on Justia Law

Norman Budge and twenty-eight additional parties (collectively, Employees) filed a complaint for review of government action for the Town of Millinocket's (Town) amendments to its personnel policy originally adopted as a town ordinance. In the most recent amendment, the Town reduced its obligation for paying for the health insurance plan for its employees and established a new policy for the health insurance offered to retirees that resulted in the Town reducing its payment of the retirees' premiums. Employees alleged that, regardless of the policy language, this reduction was inconsistent with promises made to them either when they were hired or during their tenure with the Town. The superior court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the personnel policy did not create an enforceable contract between the Town and its employees; (2) the Town was not bound to pay Employees' retirement group hospitalization and life insurance premiums by virtue of promissory estoppel; and (3) the Town's reduction in benefits did not result in an unconstitutional taking. View "Budge v. Town of Millinocket" on Justia Law

Leete & Lemieux (L&L) filed a four-count complaint against Appellant for failure to pay $10,917 for legal services rendered, plus accrued interest. The district court stayed the action until resolution by a panel of the fee arbitration commission upon a motion by Appellant. A fee arbitration panel determined that Appellant owed L&L the full amount of the unpaid fees charged, plus interest. The district court confirmed the award. Appellant appealed, asserting that the panel and the district court erred in declining to consider his claim that the statute of limitations barred L&L's recovery of fees. The Supreme Court affirmed, holding that the district court did not err in confirming the arbitration award, as (1) Defendant could have asserted the statute-of-limitations affirmative defense in his request to stay the matter pending arbitration and asked to have had that issue decided by the court prior to arbitration; and (2) therefore, Appellant was estopped from asserting a statute-of-limitations defense at this stage in the proceedings. View "Leete & Lemieux, P.A. v. Horowitz" on Justia Law