Justia Maine Supreme Court Opinion Summaries
Articles Posted in Contracts
Budge v. Town of Millinocket
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, P.A. v. Horowitz
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
Barr Jr. v. Dyke et al.
Former Bushmaster shareholders Thomas Barr Jr. and Claude Warren appealed a judgment entered in the Business and Consumer Docket in which the court granted summary judgment to all defendants on Barr and Warren’s complaint seeking rescission and other remedies based on claims of breach of fiduciary duty, fraud, unjust enrichment, and infliction of emotional distress. The court concluded that the terms of the stock purchase agreement and general release executed in settlement of Barr and Warren’s prior claims must be enforced in the circumstances of this case. The issue before the Supreme Court in this appeal was the enforceability of the contracts executed in settlement of litigation. The Court found that the minority shareholders (Barr and Warren) explicitly disclaimed reliance on the corporation and its officers and directors in determining the value of the stock that they were selling pursuant to the settlement agreement, but they sought to avoid enforcement of that disclaimer-of-reliance clause. The Court concluded that the allegations purporting to demonstrate fraud did not, in the absence of reliance, vitiate the terms of the contract of release executed between these parties, who had access to counsel, understood Bushmaster’s business, and negotiated clear terms at arm’s length in settlement of the earlier contentious lawsuit. Accordingly, the Supreme Court enforced the general release with regard to the remaining claims, and affirmed the judgment disposing of Barr and Warren’s claims. View "Barr Jr. v. Dyke et al." on Justia Law
Gray v. TD Bank, N.A.
Appellant's mother (Miller) opened a checking account with Bank. Appellant alleged that Miller added him as joint owner of the account with right of survivorship. After Miller died, Appellant withdrew all of the funds in the account. Miller's Estate brought an action against Appellant, alleging that the funds Appellant had withdrawn from the account belonged to the Estate. The probate court determined that Miller was the sole owner of the checking account and that the funds Appellant had withdrawn were the property of the Estate. The Supreme Court affirmed. Appellant later sued the Bank, seeking damages for breach of contract and negligence for failing to retain the records that would show his ownership of the account. Appellant also sought punitive damages. The superior court dismissed the action based on the doctrine of collateral estoppel, concluding that the precise issue of ownership was common to both proceedings. The Supreme Court (1) affirmed as to the breach of contract and punitive damages claims; but (2) vacated as to the negligence claim, holding that Appellant's negligence claim against the Bank was not barred by collateral estoppel, as the probate court did not adjudicate the factual issues related to this claim. View "Gray v. TD Bank, N.A." on Justia Law
Leete & Lemieux, P.A. v. Horowitz
Leete & Lemieux, P.A. (L&L) provided legal services to James Horowitz and Oxford Aviation, Inc. (collectively, Horowitz) for several years. When L&L stopped receiving payments for its services, it filed a four-count complaint against Horowitz for failure to pay $10,917 for legal services rendered, plus interest. The district court stayed the action until resolution by the fee arbitration commission. A fee arbitration panel determined that Horowitz owed L&L the full amount of the unpaid fees charges plus interest. The district court affirmed the award of the panel. Horowitz appealed, arguing that the court (1) was required to vacate the arbitration award because the panel allegedly determined that it did not have the power to decide whether L&L's claim was time-barred, and (2) erred in confirming the award because it remained within the trial court's authority to decide a statute-of-limitations defense that was not subject to arbitration and was not decided during arbitration. The Supreme Court affirmed because Horowitz did not preserve a statute-of-limitations defense at the proper procedural stage of the proceedings, and therefore, the statute-of-limitations defense was waived. View "Leete & Lemieux, P.A. v. Horowitz" on Justia Law
Travelers Indem. Co. v. Bryant
Michael Bryant, an owner and employee of Prime Cut Meat Market, assaulted another motorist, Francis Latanowich, in an apparent incident of road rage. Prime Cut and its employees were insured by a policy issued by The Travelers Indemnity Company. Latanowich and his wife sued Bryant and Prime Cut. Prime Cut successfully moved for summary judgment, and Bryant and the Latanowiches agreed to a settlement that included Bryant assigning all of his rights related to potential insurance coverage to the Latanowiches. Travelers later filed a complaint against Bryant and the Latanowiches seeking a declaratory judgment that it had no duty to indemnify Bryant for claims arising from the altercation because Bryant was not an insured under its policy issued to Prime Cut for purposes of that conduct. The superior court concluded that the policy language did not cover the incident, and it granted Travelers's motion for summary judgment. The Latanowiches appealed. The Supreme Court affirmed, holding that, pursuant to the unambiguous language of the policy, the court correctly concluded that Bryant's assault of Latanowich was not covered by the policy and properly entered summary judgment. View "Travelers Indem. Co. v. Bryant" on Justia Law
Thayer Corp. v. Me. Sch. Admin. Dist. 61
Maine School Administrative District 61 (MSAD 61) contracted with International WoodFuels for the installation of a heating system at a school owned by MSAD 61. Woodfuels contracted with Thayer Corporation to assemble and install the boiler. Thayer provided the materials and performed the work as required under the contract, but WoodFuels failed to make payments to Thayer. Thayer timely recorded a mechanic's lien against the school for the materials and services it provided to WoodFuels and subsquently filed an action to enforce the lien against WoodFuels and MSAD 61. The superior court granted MSAD 61's cross-motion for summary judgment and denied Thayer's motion for summary judgment with respect to the lien action, concluding that Thayer's services were not lienable pursuant to the mechanic's lien statute. The Supreme Court affirmed, holding that the superior court did not err in concluding that WoodFuels's heating system was not intended to become a permanent part of the school's property and was therefore not lienable by Thayer.
View "Thayer Corp. v. Me. Sch. Admin. Dist. 61" on Justia Law
McGettigan v. Town of Freeport
The town manager of the Town of Freeport signed a contract transferring the Town's emergency dispatch services to another town. Plaintiffs, two Town residents, filed an amended complaint requesting a declaratory judgment that the contract was void because it was inconsistent with section 6.10 of the Town's charter, which provides that multi-year contracts must be "made or approved by ordinance," and seeking an injunction. The Town Council later voted in favor of an ordinance that ratified the contract. The superior court subsequently dismissed the complaint, finding that the case was moot because the Town had approved the outsourcing contract by ordinance, thereby complying with section 6.10. The Supreme Court vacated the judgment and held (1) the court erred by dismissing the amended complaint because the passage of the ordinance ratifying the transfer of dispatch services contract did not render the case moot, as the contract did not conclude until the year 2016; but (2) the passage of the ordinance did satisfy the "made or approved by ordinance" requirement of section 6.10 of the charter. Remanded for entry of a judgment in favor of the Town on the merits of the amended complaint and denying the request for an injunction. View "McGettigan v. Town of Freeport" on Justia Law
A.E. Robinson Oil Co. v. County Forest Products, Inc.
Galen Porter was the sole shareholder in County Forest Products. Porter began operating a fuel delivery business as Porter Cash Fuel but never registered that name with the Secretary of State. Porter ordered fuel and gas from A.E. Robinson in a series of transactions that continued for three years. Ultimately, the business relationship deteriorated, and A.E. Robinson refused to deliver any more products. A.E. Robinson sued County Forest and Porter seeking payment on the account. Following a non-jury trial, the court entered judgment for A.E. Robinson jointly and severally against County Forest and Porter in the amount of the invoices plus financing charges and attorney fees. The Supreme Court modified the judgment to remove the award of attorney fees and affirmed as modified, holding that the trial court (1) properly held Porter and County Forest jointly and severally liable; but (2) erred in awarding attorney fees to A.E. Robinson pursuant to Me. Rev. Stat. 2-207. View "A.E. Robinson Oil Co. v. County Forest Products, Inc. " on Justia Law
Philadelphia Indem. Ins. Co. v. Farrington
Joshuah Farrington struck a moose while driving a vehicle loaned to him by Darling's Rent-a-Car, causing damages. Philadelphia Indemnity, Darling's insurer, compensated Darling's pursuant to the property damage provision of its commercial insurance policy. Philadelphia Indemnity, as Darling' subrogee, subsequently filed a complaint against Farrington, asserting that he breached the rental contract by damaging the vehicle. The Business and Consumer Docket entered judgment in Philadelphia Indemnity's favor. Farrington appealed, contending that he was insured by Darling's insurance policy with Philadelphia Indemnity and that Maine's anti-subrogation rule prohibited Philadelphia Indemnity to bring a claim against him. The Supreme Court affirmed, holding that the district court did not err in concluding that Farrington was not included as an insured within the meaning of the property damage portion of the contract Darling's made with Philadelphia Indemnity. View "Philadelphia Indem. Ins. Co. v. Farrington" on Justia Law