Justia Maine Supreme Court Opinion Summaries

A student was enrolled in a respiratory therapy program at a community college from 2017 to 2022. During her final year, supervisors at several hospitals where she completed clinical rotations reported concerns about her clinical performance, including patient safety issues and unprofessional conduct. After a series of incidents, she was suspended and ultimately dismissed from the program for violating the student code of conduct, specifically for conduct that endangered patient safety. The student argued that her difficulties were due to academic deficiencies rather than misconduct and also claimed she experienced discrimination based on her race and national origin.After her initial dismissal, the student sought review in the Somerset County Superior Court, which found the administrative record insufficient and remanded the matter for a new hearing. The college’s disciplinary committee held a second hearing, reviewed evidence from both the student and the administration, and again upheld her dismissal, explicitly finding no evidence of discrimination or bias. The student then brought a three-count action in the Superior Court: (1) an administrative appeal of her dismissal under Rule 80B, (2) a claim under 42 U.S.C. § 1983 for violation of procedural due process, and (3) a claim of unlawful educational discrimination under Maine law.The Maine Supreme Judicial Court held that the college’s decision to dismiss the student was not arbitrary or capricious and that the disciplinary process afforded her meaningful notice and an opportunity to be heard. The Court affirmed dismissal of the § 1983 and discrimination claims as duplicative of the administrative appeal, finding that her grievances were properly addressed through Rule 80B review, and that there was no evidence of discrimination or due process violations. The judgment of the Superior Court was affirmed. View "Hogan v. Kennebec Valley Community College" on Justia Law

The Maine Supreme Judicial Court ruled in favor of the University of Maine System (UMS) in a case involving Robert Bocko, who claimed that UMS failed to pay him wages on time as mandated by Maine law. Bocko, who was employed by UMS to teach law courses, argued that UMS violated the state's wage payment laws by not paying him at intervals not exceeding 16 days. UMS countered that Bocko was exempt from these requirements as he was a salaried employee. The court agreed with UMS, ruling that Bocko was indeed exempt from the wage payment requirements as he was compensated on a fee basis for teaching each course, rather than on a regular salary basis. The court found that the payment Bocko received for teaching each course met the salary-basis requirement when converted to an annual rate. Therefore, the court affirmed the Superior Court's judgment in favor of UMS. View "Bocko v. University of Maine System" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court determining that the Town of Frye Island may not withdraw from Maine School Administrative District 6 (MSAD 6) in the absence of legislation expressly authorizing the Town to invoke the statutory withdrawal process set forth in Me. Rev. Stat. 20-A, 1466, holding that the superior court did not err.The residents of Frye Island voted unanimously to withdraw from MSAD 6. The Legislature responded by enacting L.D. 500, which stated that the Town could not withdraw from MSAD 6 unless withdrawal was first authorized. Frye Island later amended its charter and again sought to withdraw from MSAD 6. MSAD 6 sought a declaratory judgment that Frye Island's effort to withdraw from MSAD 6 was unlawful. The court granted summary judgment for MSAD 6. The Supreme Judicial Court affirmed, holding (1) the amendment to the Town's charter did not expressly or implicitly repeal L.D. 500 by operation of law; (2) L.D. 500 does not violate the Maine Constitution's special legislation clause; and (3) the court did not err in dismissing Frye Island's claims arising under the Due Process Clause and Equal Protection Clause of the United States and Maine Constitutions. View "MSAD 6 Board of Directors v. Town of Frye Island" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court on a complaint filed by Thornton Academy and residents of Arundel (collectively, Plaintiffs) in connection with the decision of Regional School Unit 21 and its Board (collectively, RSU 21) not to allow Arundel middle school students to attend Thornton Academy at public expense, holding that the court did not misinterpret Me. Rev. Stat. 20-A, 1479.In their complaint, Plaintiffs sought a declaratory judgment that RSU 21 incorrectly interpreted and applied Me. Rev. Stat. 21-A, 1479 in deciding that all Arundel public middle school students must attend the Middle School of the Kennebunks and that public funds cannot be used for those students to attend Thornton Academy. The superior court concluded that, pursuant to Me. Rev. Stat. 21-A, 1479(3)(A), RSU 21 must continue to allow Arundel middle school students to attend Thornton Academy at public expense. The Supreme Judicial Court affirmed, holding that section 1479(3)(A) requires RSU 21 to provide the option for Arundel middle school students to attend Thornton Academy at public expense. View "Thornton Academy v. Regional School Unit 21" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court on consolidated Rule 80C appeals from the decision of the Maine Labor Relations Board (MLRB) on the School Administrative District 3 Education Association MEA/NEA’s (the Association) prohibited practice complaint, holding that the MLRB did not err when it held that the 120-day notice provision in Me. Rev. Stat. 26, 965(1) applied to the request for impact bargaining in this case.The Association filed a prohibited practice complaint with the MLRB against the Board of Directors of Regional School Unit 3 (the School Board), alleging that the School Board violated Me. Rev. Stat. 26, 964(1)(E) and 965(1) when it refused to participate in mediation and fact-finding procedures with respect to the effect of a new bus system. The MLRB determined that the Association failed to comply with the 120-day notice requirement in section 965(1) by failing to participate in fact-finding concerning the impact of the new busing system. The superior court affirmed. The Supreme Judicial Court affirmed, holding that the MLRB did not clearly err in finding that the Association did not provide adequate notice to satisfy section 965(1). View "SAD 3 Education Ass’n v. RSU 3 Board of Directors" on Justia Law

A district elementary school principal interpreted an educational policy to mean that elementary school teachers were expected to be present in their classrooms ten minutes before the start of the instructional day. The Coastal Education Association, an affiliate of a union representing teachers, filed a grievance with Regional School District Unit No. 5 (RSU No. 5) challenging the principal’s interpretation as a violation of the collective bargaining agreement (CBA) between the Association and the Board of Directors of RSU No. 5. An arbitrator concluded that the principal’s directive violated the CBA and directed RSU No. 5 to rescind the educational policy. RSU No. 5 filed an application to vacate the arbitration award. The superior court granted the application, concluding that the dispute was not substantively arbitrable pursuant to the Municipal Public Employees Labor Relations Law, which prevents school boards from bargaining on matters of educational policy or submitting educational policy disputes to interest arbitration. The Supreme Judicial Court affirmed, holding that the trial court did not err in concluding that the educational policy at issue in this case was, as a matter of law, not substantively arbitrable. View "Reg’l Sch. Unit No. 5 v. Coastal Educ. Ass’n" on Justia Law

A district elementary school principal interpreted an educational policy to mean that elementary school teachers were expected to be present in their classrooms ten minutes before the start of the instructional day. The Coastal Education Association, an affiliate of a union representing teachers, filed a grievance with Regional School District Unit No. 5 (RSU No. 5) challenging the principal’s interpretation as a violation of the collective bargaining agreement (CBA) between the Association and the Board of Directors of RSU No. 5. An arbitrator concluded that the principal’s directive violated the CBA and directed RSU No. 5 to rescind the educational policy. RSU No. 5 filed an application to vacate the arbitration award. The superior court granted the application, concluding that the dispute was not substantively arbitrable pursuant to the Municipal Public Employees Labor Relations Law, which prevents school boards from bargaining on matters of educational policy or submitting educational policy disputes to interest arbitration. The Supreme Judicial Court affirmed, holding that the trial court did not err in concluding that the educational policy at issue in this case was, as a matter of law, not substantively arbitrable. View "Reg’l Sch. Unit No. 5 v. Coastal Educ. Ass’n" on Justia Law

Michael Doyle submitted to the Town of Falmouth a request pursuant to the Freedom of Access Act (FOAA) seeking to inspect certain cellular telephone bills of the School Department’s former Superintendent. The former Superintendent provided the requested records but redacted the information she considered nonpublic and confidential, exempt from disclosure pursuant to the FOAA, or beyond the scope of Doyle’s request. Doyle appealed, alleging that he was entitled to received unredacted copies of the cellular telephone records. After an in camera review of the unredacted records, the superior court entered judgment in favor of the Town and School Department. The Supreme Court affirmed, holding that the personal telephone numbers of public employees, any information concerning calls other than those related to the Town’s business, and any records containing information about parents’ and students’ telephone numbers were properly redacted from the Town’s response to the FOAA request. View "Doyle v. Town of Falmouth" on Justia Law

John and Jane Doe, the parents Susan Doe, a transgender girl, filed a complaint with the Maine Human Rights Commission alleging that Regional School Unit 26 (RSU 26) had violated the Maine Human Rights Act (MHRA) by excluding Susan from the communal girls’ bathroom at elementary and middle school. The Commission found reasonable grounds to believe discrimination had occurred. Thereafter, the Does and the Commission filed a complaint in the superior court asserting claims for unlawful discrimination in education (Count I) and unlawful discrimination in a place of public accommodation (Count II) on the basis of sexual orientation. The superior court granted RSU 26’s motion for summary judgment on all counts. The Supreme Court vacated the judgment of the superior court, holding that where it has been clearly established that a student’s psychological well-being and educational success depend on being permitted to use the communal bathroom consistent with her gender identity, denying the student access to the appropriate bathroom constitutes sexual orientation discrimination in violation of the MHRA. Remanded for entry of summary judgment for the Does and the Commission. View "Doe v. Reg'l Sch. Unit 26" on Justia Law

D.S., who had several disabilities and disorders, was admitted to the Spurwink School for the provision of "necessary emotional, psychological and other therapeutic services and education." In 2004, D.S., then sixteen years old, arrived at school. An educational technician came outside when D.S. arrived, but D.S. shortly thereafter left the property on foot. D.S. was not located, and D.S. later alleged that, after leaving the school property, she was sexually assaulted by two strangers. In 2010, D.S.'s mother, on behalf of D.S., filed a five-count complaint against Spurwink Services. Spurwink Services moved to dismiss the complaint, asserting that the case was governed by the Maine Health Security Act (MHSA) and D.S. failed to comply with the requirements of the MHSA. The superior court entered summary judgment in favor of Spurwink Services, finding that it lacked jurisdiction over D.S.'s claims pursuant to the MHSA. The Supreme Court vacated the judgment and remanded, holding that the provisions of MHSA did not apply in this case, as D.S.'s action did not constitute an "action for professional negligence" as defined by the MHSA. View "D.S. v. Spurwink Services, Inc." on Justia Law