Justia Maine Supreme Court Opinion Summaries

High Maine, LLC, challenged the Town of Kittery's issuance of a marijuana retail store license and approval of a change of use and modified site plan for GTF Kittery 8, LLC, to operate a marijuana retail store in the Town’s C-2 zone. High Maine argued that the Town's actions violated local and state regulations, particularly concerning the proximity of the proposed store to a nursery school.The Superior Court (York County) dismissed High Maine's complaint for lack of standing, reasoning that High Maine, as a pre-applicant on the waiting list for a marijuana retail store license, did not suffer a particularized injury. The court concluded that High Maine's status as a prospective license-holder was unchanged by the Town's decisions, and thus, it was not directly affected.The Maine Supreme Judicial Court reviewed the case and determined that High Maine had alleged a particularized injury sufficient to establish standing. The court noted that High Maine's opportunity to obtain the single license available in the C-2 zone was directly and negatively affected by the alleged defects in the licensing process. The court found that High Maine's complaint suggested that GTF Kittery 8 obtained an unfair advantage in the lottery by submitting multiple applications for the same building, which was within 1,000 feet of a school, in violation of state law.The Maine Supreme Judicial Court vacated the Superior Court's judgment and remanded the case for further proceedings, holding that High Maine's allegations were sufficient at the motion to dismiss stage to demonstrate its standing to challenge the Town's actions. View "High Maine, LLC v. Town of Kittery" on Justia Law

Steve L. Michaud sustained a traumatic injury to his left eye on December 26, 2014, while working as an auto mechanic, resulting in an immediate loss of more than eighty percent of his vision. Michaud underwent multiple surgeries between 2015 and 2019 in an attempt to restore his vision, but these efforts were largely unsuccessful. In September 2021, Michaud filed petitions for an award of compensation and specific-loss benefits. A doctor’s report in October 2021 confirmed that Michaud had reached maximum medical improvement (MMI) with a ninety-four percent vision loss in his left eye.An Administrative Law Judge (ALJ) determined that Michaud’s specific-loss benefits became due on October 14, 2021, the date of the doctor’s report, and ordered interest to be paid from that date. Michaud appealed, arguing that the benefits should accrue from the date of his injury in 2014. The Workers’ Compensation Board (WCB) Appellate Division affirmed the ALJ’s decision, relying on the precedent set in Tracy v. Hershey Creamery Co., which held that specific-loss benefits for an eye injury are determined when the injury reaches a reasonable medical endpoint.The Maine Supreme Judicial Court reviewed the case and found that Michaud’s injury immediately resulted in more than eighty percent vision loss and that his condition did not materially improve despite medical interventions. The court held that Michaud’s specific-loss benefits became due on the date of his injury, December 26, 2014, and that interest should accrue from that date. The court vacated the Appellate Division’s decision and remanded the case for entry of a decree ordering Michaud’s employer to pay interest from the date of the injury. View "Michaud v. Caribou Ford-Mercury, Inc." on Justia Law

The Industrial Energy Consumer Group (IECG) appealed an order from the Public Utilities Commission (PUC) regarding the recovery of costs related to power supply obligations and state energy programs. The PUC decided that these costs should be recovered volumetrically from all ratepayer classes, except for one category, which should be recovered using a fixed customer charge. IECG argued that the order was preempted by the Federal Power Act and that the allocation and design violated cost-causation principles and state statutes.The Office of the Public Advocate contended that IECG’s appeal was untimely and should be dismissed. The PUC argued that the appeal was an improper collateral attack on a prior rate order. Both the Public Advocate and the PUC maintained that if the merits were considered, the order should be affirmed as rational and supported.The Maine Supreme Judicial Court concluded that the appeal was timely and not barred by collateral estoppel. The court did not address the preemption argument, finding it unpreserved for appellate review. The court rejected IECG’s arguments on the merits, noting the deferential standard of review for the PUC’s expert judgment in ratemaking. The court found that the PUC’s decision to treat NEB costs separately from traditional T&D service costs was rational and supported by the record. The court also determined that the PUC’s allocation and rate design did not violate state statutes.The court affirmed the PUC’s order, holding that the PUC’s approach to NEB cost recovery was within its broad discretion and sufficiently justified. The court noted that the PUC might refine its approach in the future based on further data collection and party input. View "Industrial Energy Consumer Group v. Public Utilities Commission" on Justia Law

Patrick Gordon, an attorney, was suspended from the rosters of the Maine Commission on Public Defense Services, making him ineligible to represent indigent criminal defendants. The suspension followed an investigation into Gordon’s billing practices and representation of a client. The Commission received information suggesting that Gordon had inaccurately billed for a jury trial that was actually a bench trial and that some billed work was performed by others in his firm. Additionally, there were discrepancies regarding Gordon’s client visits.The Superior Court (Kennebec County) affirmed the Commission’s decision. The investigation began after the Commission received information from a post-conviction review counsel. Gordon was asked to provide documents and clarify billing discrepancies but failed to fully comply. Despite multiple requests and extensions, Gordon did not provide the requested documents or satisfactory explanations. The Commission’s Interim Executive Director, Justin Andrus, ultimately suspended Gordon, a decision upheld by the Commission after an intra-agency appeal.The Maine Supreme Judicial Court reviewed the case and affirmed the Superior Court’s judgment. The Court found that the Commission’s decision was not arbitrary or capricious. The evidence showed that Gordon failed to comply with the Commission’s requests, which were within the Commission’s authority. The investigation and subsequent suspension were justified based on Gordon’s non-compliance with the Commission’s rules. The Court concluded that the Commission’s decision was supported by evidence and did not reflect any abuse of discretion or erroneous findings of fact. View "Gordon v. Maine Commission on Public Defense Services" on Justia Law

The case involves a dispute over the Town of Bar Harbor's decision to present several proposed changes to its municipal charter as separate questions to voters, rather than as a single package. The changes were recommended by a charter commission and included modifications to various areas of the town's governance. A group of voters, led by Michael Good, challenged this approach, arguing that the changes were not "minor modifications" and should have been presented as a single "revision" of the charter.The Superior Court (Hancock County, Anderson, J.) agreed with Good and nullified the changes, ruling that they were not minor modifications and should have been presented as a single revision. The court also found procedural irregularities in how the changes were developed and submitted.On appeal, the Maine Supreme Judicial Court disagreed with the lower court's interpretation. The court held that the charter commission acted legally in determining that its recommendations constituted minor modifications and proposing that they be submitted to the voters in nine separate articles. The court also found that none of the claimed procedural irregularities nullified the vote. Therefore, the court vacated the lower court's judgment and remanded the case for the court to enter a judgment for the Town on Good’s complaint. View "Good v. Town of Bar Harbor" on Justia Law

Wade T. Hamilton, a pediatric cardiologist, recommended a patient for a cardiac MRI scan but warned her that due to her COVID-19 vaccination, which he claimed included "magnets and heavy metals", it would be unsafe for her to enter an MRI machine. The patient's mother reported Hamilton's statements to the nurse practitioner who had referred the patient to Hamilton, leading to a report being filed against Hamilton with the Board of Licensure in Medicine. The Board, in response, opened a complaint proceeding and demanded that Hamilton undergo a neuropsychological evaluation.Hamilton challenged the Board's order in the Superior Court, arguing that the Board had overstepped its authority and violated his rights to due process and free speech. However, the Superior Court denied his petition and ruled in favor of the Board. Shortly before this decision, Hamilton's medical license in Maine expired and he did not renew it.The Maine Supreme Judicial Court dismissed Hamilton's appeal as nonjusticiable, stating that there had been no final agency action and that the challenged order was moot because Hamilton had allowed his medical license to lapse. The court also noted that Hamilton's challenge to the order directing the evaluation was fully reviewable at the conclusion of the complaint proceedings, making his petition premature. Furthermore, since Hamilton was no longer licensed in Maine, the Board no longer had authority to pursue his evaluation. The court vacated the judgment and remanded the case to the Superior Court for dismissal of the petition for judicial review as nonjusticiable. View "Hamilton v. Board of Licensure in Medicine" on Justia Law

The case involves Dennis G. Crosen, a former employee of Blouin Motors, Inc., who suffered two work-related injuries in 1984 and 2002, respectively. The 1984 injury occurred while Crosen was working for Rockingham Electric, Inc., and the 2002 injury occurred while he was working for Blouin Motors, Inc. The two injuries combined to render Crosen totally incapacitated. A hearing officer apportioned 40% of the responsibility for Crosen's incapacity to Rockingham and 60% to Blouin. In 2014, Crosen began collecting old-age insurance benefits under the United States Social Security Act. By statute, Blouin's obligation to pay weekly incapacity benefits based on the 2002 injury was to be reduced by half of the amount of Social Security benefits that Crosen receives. No Social Security offset applies to the compensation that Rockingham owes for the 1984 injury.The Administrative Law Judge (ALJ) and the Workers’ Compensation Board Appellate Division denied Blouin's petition to apply the entire Social Security offset to its compensation payments to Crosen. The ALJ and the Appellate Division interpreted the relevant statute to mean that Blouin could only apply the offset to the portion of the benefits for which it was responsible (60%), not the entire amount.The Maine Supreme Judicial Court disagreed with the lower courts' interpretation of the statute. The court held that Blouin was entitled to take the full offset provided by the statute, not just the portion corresponding to its share of responsibility for Crosen's incapacity. The court vacated the decision of the Appellate Division and remanded the case for further proceedings. The court also noted that Blouin may be entitled to a credit for the portion of the offset that it did not take prior to this case, but left this issue to be resolved on remand. View "Crosen v. Blouin Motors., Inc." on Justia Law

The case involves a group of plaintiffs, led by Chris Calnan, who challenged a rule implemented by Maine Emergency Medical Services (Maine EMS) requiring emergency medical service (EMS) workers to be fully vaccinated against COVID-19 and influenza. The plaintiffs sought a declaratory judgment that Maine EMS lacked statutory authority to implement such a rule.The Superior Court (Kennebec County) dismissed the plaintiffs' complaint. The court concluded that the plaintiffs had named the correct defendants, that it had jurisdiction to consider the challenge to the rulemaking, and that the EMS Board acted within its authority in implementing the immunization rule. The court also dismissed the plaintiffs' motion for summary judgment as moot.On appeal, the Maine Supreme Judicial Court affirmed the lower court's decision. The court found that the EMS Board did not exceed its statutory authority in issuing the immunization rule. The court also concluded that the rule aligns with the purpose of the Maine Emergency Medical Services Act of 1982, which is to ensure optimum patient care and the safe handling and transportation of patients. Lastly, the court determined that the EMS Board followed the applicable rulemaking process for the promulgation of the immunization rule. View "Calnan v. Hurley" on Justia Law

The case centers around the dispute over the requirement for a supermajority vote in the Town of Bar Harbor's amendment to its Land Use Ordinance (LUO) concerning vacation rentals. Erica Brooks and Victoria Smith, both property owners in the town, argued that due to a 2-2 tie vote by the Planning Board on the proposed amendment, a two-thirds majority vote was necessary for the amendment to pass. The amendment, however, was enacted with a 60% majority vote. The Superior Court sided with the Town, asserting that the LUO language did not necessitate a supermajority vote.On appeal, the Maine Supreme Judicial Court affirmed the lower court's decision but did so on different grounds. The court agreed with the argument put forth by the Maine Municipal Association in an amicus brief, which asserted that irrespective of the LUO's language, under Maine statutes 21-A M.R.S. § 723(4) (2023) and 30-A M.R.S. § 2501 (2023), only a simple majority vote was required for the amendment to take effect, unless the Town's charter provided otherwise, which it did not. Therefore, the court concluded that the amendment was lawfully enacted with a simple majority vote, rendering the Town's supermajority requirement unenforceable. View "Brooks v. Town of Bar Harbor" on Justia Law

In this case before the Maine Supreme Judicial Court, the Office of the Public Advocate (OPA) contested an order by the Public Utilities Commission (Commission) that extended the waiver of the standard depreciation rate for the Maine Water Company - Millinocket Division (MWC). The OPA raised three claims: (1) the Commission erred in applying Chapter 110 of its rules to waive the depreciation rate set in Chapter 68, which according to the OPA already contained a waiver provision; (2) the Commission abused its discretion and set unjust and unreasonable rates by approving an arbitrarily low depreciation expense; and (3) the Commission relied on information that was not included in the evidentiary record.The court disagreed with all three claims raised by the OPA. Regarding the first claim, the court stated that Chapter 68 did not contain a waiver provision and that the Commission rightly applied the general waiver provision contained in Chapter 110. Concerning the second claim, the court found that the Commission did not abuse its discretion when it extended the waiver in anticipation of a gradual return to full depreciation expenses. The court determined that the Commission's decision aligned with the statutory rate-setting goal and prevented rate shock. Lastly, the court determined that the OPA waived its third claim by not raising the issue about the lack of an evidentiary record earlier in the proceedings. As such, the court affirmed the Commission's order. View "Office of the Public Advocte v. Public Utilities Commission" on Justia Law