Justia Maine Supreme Court Opinion Summaries

The Department of Health and Human Services filed a petition seeking a general public guardianship over Colleen McIntosh, alleging that McIntosh’s diagnosis of chronic paranoid schizophrenia rendered her incapacitated. After a hearing, the county probate court appointed the Department as general public guardian for McIntosh based on its findings that McIntosh was incapacitated and in need of a full guardianship until her condition became adequately controlled and that there was no suitable private person available to fulfill that need. The Supreme Judicial Court affirmed, holding that there was ample evidence supporting a finding, under the clear and convincing evidence standard, of each of the elements necessary for issuance of an order appointing the Department as McIntosh’s public guardian. View "In re Guardianship of McIntosh" on Justia Law

Steven L. was ordered involuntarily committed to a hospital for up to ninety days. During the term of commitment, the hospital applied for an order directing Steven’s involuntary admission to a progressive treatment program. After an evidentiary hearing, the district court ordered Steven admitted to the progressive treatment program for twelve months. The superior court affirmed the judgment. Steven appealed to the Supreme Court. Before the appendix, appellee’s brief, and reply brief were due in the appeal, Steven was discharged when the progressive treatment program’s term expired. The Supreme Court dismissed the appeal as moot because Steven had been discharged and the progressive treatment program had expired and because none of the exceptions to the mootness doctrine applied. View "In re Steven L." on Justia Law

Plaintiff filed an unsworn notice of claim with the superior court pursuant to the Maine Health Security Act (MHSA) alleging that Defendants were negligent in providing her medical care. The statute of limitations on Plaintiff's claim subsequently expired. Thereafter, Plaintiff served her unsworn notice of claim to Defendants. Plaintiff then filed a sworn notice of claim. The superior court subsequently dismissed Plaintiff's unsworn notice of claim on the ground that the defective notice failed to toll the applicable statute of limitations. The Supreme Court vacated the judgment and remanded, holding that Plaintiff should be permitted to amend her notice of claim pursuant to Me. R. Civ. P. 15 and to have the amendment relate back to the original filing date. View "Frame v. Millinocket Reg'l Hosp." on Justia Law

Plaintiff was employed by a Hospital for nineteen years. In 2009, Plaintiff was deposed in connection with a wrongful death lawsuit against the Hospital. The day after Plaintiff signed her deposition transcript, the Hospital terminated Plaintiff's employment on the ground that a medical record entry Plaintiff described in her deposition constituted a falsification of a patient medical record. Plaintiff filed a complaint against the Hospital, alleging that it violated Me. Rev. Stat. 26, 833(1)(C) because it discharged her in retaliation for her deposition testimony in the wrongful death lawsuit against the Hospital. The superior court granted summary judgment in favor of Hospital. The Supreme Court vacated the judgment, holding that Plaintiff presented sufficient evidence to create a genuine issue of material fact regarding whether her deposition was a substantial factor motivating her dismissal. View "Trott v. H.D. Goodall Hosp." 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

The Department of Health and Human Services filed petitions seeking the appointment of a public guardian and conservator for Helen F. After a hearing, the county probate court adjudicated Helen to be incapacitated and appointed the Department as Helen's public guardian and conservator. Helen appealed. The Supreme Court vacated the judgment, holding (1) Helen's case was before the Court without any acceptable record of the proceedings below; and (2) the trial court's inability to remember Helen's case, and Helen's corresponding inability to provide an adequate statement of the evidence was no fault of Helen's. Remanded for a de novo adjudication of Helen's capacity. View "In re Guardianship of Helen F." on Justia Law

Police brought Marcia E. to a Hospital's emergency room after Marcia lit herself on fire. Medical staff evaluated Marcia and determined that she meet the criteria for emergency involuntary admission pursuant to Me. Rev. Stat. 34-B, 3863. It was not until the third day, when the Hospital could accommodate Marcia in its psychiatric unit, that Hospital officials applied for the judicial endorsement necessary to formally admit Marcia to the Hospital on an emergency basis. The court gave its endorsement. Two days later, the Hospital filed an application for Marcia's involuntary commitment. Marcia sought dismissal of the petition on the basis that the Hospital violated the statutory procedure for emergency hospitalization by holding her for three days before seeking the judicial endorsement. The court denied Marcia's motion to dismiss and ordered Marcia's hospitalization. The superior court affirmed. The Supreme Court affirmed, holding that the Hospital's failure to comply with the procedural requirements for Marcia's emergency admission did not constitute grounds for dismissal of the separate involuntary commitment petition, as the Hospital met all the requirements necessary to involuntarily commit Marcia. View "In re Marcia E." on Justia Law

In this appeal, the question presented to the Supreme Court based on the facts of this case was: "[w]hen a physician is alleged to have acted as an apparent agent of a hospital, does the Maine Health Security Act require that the alleged negligent acts or omissions of that physician be evaluated by the mandatory prelitigation screening and mediation panel before a claim may be brought in court against the hospital based on that physician’s conduct? The Court answered that question in the affirmative: "[b]ecause Maine law requires that a prelitigation screening panel evaluate a physician's alleged professional negligence before consideration at trial, and because that did not occur in the instant case," the Court vacated the judgment and remanded the case for further proceedings. View "Levesque v. Central Maine Medical Center" on Justia Law

Mrs. T. was the mother of C.T., a fifteen-year-old boy with severe disabilities. At issue in this case was C.T.'s eligibility for the Department of Health and Human Services' home and community-based waiver program. C.T. was approved for the waiver program but was not receiving services under the waiver when the Department instituted a new regulation that closed the program to children but grandfathered children who were already receiving services. Mrs. T. subsequently filed a grievance with the Department seeking to have C.T. declared waiver-eligible. The Commissioner of the Department accepted the recommendation of an administrative hearing officer that denied the grievance. The superior court affirmed. Mrs. T. appealed, contending that the Department was equitably estopped from denying services because she reasonably relied to her detriment on misinformation she received that C.T. was eligible. The Supreme Court affirmed, holding that because Mrs. T. did not meet her burden to prove that her reliance on the misinformation given to her by the Department caused any detriment to C.T., the hearing officer did not err in finding that the Department was not equitably estopped from declaring C.T. ineligible for a waiver. View "Mrs. T. v. Dep't of Health & Human Servs." on Justia Law

The State filed an antitrust enforcement action against four MaineHealth entities based on the proposed acquisition by MaineHealth of two major cardiology practices. The matter was transferred to the business and consumer docket. Central Maine Medical Center (CMMC) moved to intervene in the proceeding, arguing that it had an interest in the case as a principal competitor in cardiovascular surgery of one of MaineHealth's hospitals. The lower court denied CMMC's motion. The Supreme Court affirmed the denial of CMMC's motion, holding (1) because CMMC made no evidentiary showing of bad faith, collusion, or other malfeasance on the part of the government, and did not demonstrate that the disposition of the antitrust action would impair its ability to protect its interests through independent litigation, intervention of right was properly denied; and (2) the lower court did not err in denying permissive intervention after determining that joining the private cause of action to the State's enforcement claim would unduly burden the proceedings and supplying an alternative method for CMMC to participate in the action by providing oral comments and written submissions to the court. View "State v. MaineHealth" on Justia Law