Justia Maine Supreme Court Opinion Summaries

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

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 Miller's Estate brought an action against Appellant, alleging that the funds Appellant had withdrawn from the account belonged to the Estate. The probate court determined that Miller was the sole owner of the checking account and that the funds Appellant had withdrawn were the property of the Estate.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. (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

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

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

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

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

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

Husband and Wife divorced in 1989 pursuant to a divorce judgment that incorporated an agreement dividing the parties' property. Husband retired from the Air National Guard in 2002 and began collecting his retirement benefits in 2006. In 2010, Wife filed a motion to modify the divorce judgment, requesting that the district court specify the amount of Husband's military pension to which she was entitled. The court granted the motion and awarded a portion of Husband's benefits to Wife after concluding that the provision of the divorce judgment regarding Husband's military pension was ambiguous. The Supreme Court vacated the judgment of the district court, holding that the provision awarding Husband his military pension was unambiguous and that Wife's motion to modify was improperly granted. Remanded. View "Burnell v. Burnell" on Justia Law

Robert Laux and Cynthia Moran-Laux (collectively Laux) appealed, and Ralph Harrington cross-appealed, from a judgment of the superior court declaring the continued existence and location of a road easement in favor of Harrington over Laux's property and awarding Harrington nominal damages for Laux's interference with the use of the easement. Laux asserted that a 1990 quitclaim deed given by Harrington's predecessor-in-title to Laux's predecessor-in-title extinguished the easement, or, alternatively, that construction on the site of its original entry point resulted in its abandonment. Harrington contended that the court erred in excluding certain evidence at trial, resulting in its miscalculation of his damages and failure to award punitive damages. The Supreme Court affirmed the judgment, holding, inter alia, that the superior court did not err in (1) finding that the 1990 quitclaim deed was not intended to release Harrington's easement over the land now owned by the Lauxes; (2) concluding that Harrington did not abandon his easement; (3) calculating damages; and (4) finding that Laux's conduct did not rise to the level of actual ill will or outrageousness required to award punitive damages. View "Laux v. Harrington " on Justia Law