Justia Maine Supreme Court Opinion Summaries

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 The court rescinded the contract and ordered Prime to refund Seacoast and Seacoast to return the vehicle to Prime.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

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