Justia Maine Supreme Court Opinion Summaries

Plaintiff, who was injured when the car she was driving was rear-ended by an underinsured motorist, claimed uninsured/underinsured motorist coverage and medical payments coverage under two State Farm Mutual Automobile Insurance Company policies. An arbitration panel found that the accident caused Plaintiff $378,000 in damages, $125,000 of which were identified as medical costs. The parties' dispute regarding the extent of coverage available to Plaintiff proceeded to trial. The superior court determined that only one of the State Farm policies covered Plaintiff, deferred to the arbitration award as to Plaintiffs' actual damages, established the amount owed by State Farm, and reduced the arbitration award accordingly. The Supreme Court affirmed in part and vacated in part, holding (1) the superior court correctly determined that only one of the policies covered Plaintiff, but (2) the court’s decision regarding the amount due under that policy was in error. Remanded. View "Graf v. State Farm Mut. Auto. Ins. Co." on Justia Law

Plaintiff was driving her car when she was struck from behind from an underinsured motorist. Plaintiff claimed uninsured/underinsured (UM/UIM) coverage and medical payments under two State Farm Mutual Automobile Insurance Company policies and filed a complaint against State Farm seeking coverage pursuant to both policies. The parties agreed to arbitrate the amount of damages caused by the accident but to have a court decide any issues relating to the amount of UM/UIM coverage available to Plaintiff through the policies. An arbitration panel found that the accident caused Plaintiff damages of $378,000. Thereafter, the superior court concluded that Plaintiff had UM/UIM coverage under only one of the State Farm policies, deferred to the arbitration award as to Plaintiff’s actual damages, determined that she was entitled to $250,000 from State Farm, and reduced the arbitration award accordingly. The Supreme Judicial Court affirmed in part and vacated in part, holding that the superior court did not err in concluding that Plaintiff was entitled to coverage under only one of the State Farm policies but erred in deciding calculating the amount due under that policy. Remanded. View "Graf v. State Farm Mut. Auto. Ins. Co." on Justia Law

Arthur Murdock, then a lieutenant with the Maine State Police, was injured when his cruiser was struck by another vehicle after Martin Thorne indicated that Murdock could turn in front of him into an intersection. Murdock filed a four-count complaint alleging negligence against Castigliola and Thorne and seeking uninsured motorist coverage from the Maine Department of Public Safety (DPS). The superior court granted the motions for summary judgment filed by both DPS and Thorne. Murdock appealed, and DPS cross-appealed. The Supreme Judicial Court dismissed the appeals, holding that the superior court improvidently granted Murdock’s motion to enter final judgment on Murdock’s claims against Thorne and DPS pursuant to Me. R. Civ. P. 54(b)(1). View "Murdock v. Thorne" on Justia Law

Paul Galipeau was involved in a fatal accident while riding his motorcycle. Galipeau and his wife were insured under four vehicle policies issued by State farm, one on the motorcycle and the others covering three different vehicles. Each of the policies provided uninsured motorist (UM) coverage with a per-person limit of $100,000. The Estate demanded from State Farm the aggregate of each policy’s UM coverage limit, less the $50,000 recovered from the tortfeasor. State Farm paid the differential between the motorcycle policy UM limit and the amount already recovered by the Estate and otherwise refused the demand. The Estate subsequently sued State Farm for wrongful denial of coverage. The superior court entered judgment for State Farm, ruling that coverage under the three non-motorcycle policies was precluded by an “other-owned-vehicle” exclusion that each policy contained. The Supreme Court affirmed, holding that the superior court did not err in entering summary judgment for State Farm on the ground that the other-owned-vehicle exclusion in the four policies precluded coverage under the three non-motorcycle policies. View "Estate of Galipeau v. State Farm Mut. Auto. Ins. Co." on Justia Law

William Googins committed an intentional assault of Eric Benson, which resulted in Benson’s death. Benson’s estate sued Googins in tort. Googins consented to a judgment in favor of the Estate and assigned to the Estate all rights he may have had against Metropolitan Property and Casualty Insurance Company, whose potential liability stemmed from a homeowner’s policy it issued to Goggins’s grandmother that was active at the time of the assault. Pursuant to the agreement, the superior court entered a judgment against Googins, after which the Estate filed a reach-and-apply action against Metropolitan. Metropolitan filed a complaint for declaratory judgment seeking a determination as to its obligation to indemnify Googins. The superior court granted summary judgment in favor of Metropolitan, declaring that it had no contractual obligation to indemnify Googins. Specifically, the court found that the claim was precluded by an intentional loss exclusion because Googins intentionally assaulted Benson. The Supreme Judicial Court affirmed, holding that the superior court did not err in determining that Googins’s conduct was within the scope of the intentional loss exclusion. View "Metro. Prop. & Cas. Ins. Co. v. Estate of Benson" on Justia Law

Wife was a passenger on a motorcycle operated by Husband when she was injured in an accident. At the time, Wife and Husband were named insureds on a motorcycle insurance policy from Insurer. Wife filed a complaint against Husband alleging negligence in connection with the accident. A jury found Husband negligent and awarded Wife $50,000 in damages. Husband moved to amend the judgment to obtain a credit for the amount in prejudgment payments that the Insurer had made to Wife. The superior court granted Husband’s motion to amend the judgment. Wife appealed, arguing that the court erred in interpreting Me. Rev. Stat. 24-A, 2426 to allow Husband a credit against the judgment for the medical payments maximum coverage of what Insurer had already paid to Wife’s medical providers before this action was commenced. The Supreme Judicial Court vacated the order amending judgment, as the court did not determine whether the payments Insurer paid Wife’s medical providers were medical or liability payments. Remanded for a factual determination of the type of prepayments Insurer made, whether liability payments pursuant to Husband’s policy, medical payments pursuant to Wife’s policy, or some other type of payment. View "Wood v. Wood" on Justia Law

When Mark Chartier and Lisa Heward were married, Chartier purchased an annuity policy from Farm Family Life Insurance Co. for which he named Heward as primary beneficiary. Heward later requested the cash value of the annuity to Farm Family by signing Chartier’s name on the form. Farm Family issued a check payable to Chartier in the requested amount, Heward deposited the check into her and Chartier’s joint account with Gorham Savings Bank, and then withdrew $40,000 from the joint account. That same day, Heward informed Chartier that she wanted a divorce. Chartier filed a complaint against Farm Family, Gorham Savings Bank, and Farm Family’s sales agent, alleging breach of fiduciary duty, breach of the implied covenant of good faith and fair dealing, and negligence. The superior court granted summary judgment in favor of the defendants as to all counts. The Supreme Judicial Court affirmed, holding that summary judgment was properly entered in the defendants’ favor as to all counts. View "Chartier v. Farm Family Life Ins. Co." on Justia Law

James Dickau was injured when he was struck by a vehicle driven by Irida Macomber. At the time of the accident, Dickau was covered by two insurance policies - a Dairyland Insurance Company policy and a Vermont Mutual personal umbrella policy. Dickau settled his claim against Macomber for her policy limit and also settled his claim for uninsured motorist benefits with Dairyland. Dickau then sought a declaratory judgment that his umbrella policy with Vermont Mutual provides for uninsured motorist coverage, and alternatively, that Vermont Mutual was required to provide uninsured motorist coverage under statute. The superior court granted Vermont Mutual’s motion for summary judgment. The Supreme Court affirmed, holding (1) Dickau’s umbrella policy with Vermont Mutual itself unambiguously provides no UM coverage; and (2) Maine’s UM statute does not require Vermont Mutual to provide UM coverage in the umbrella policy. View "Dickau v. Vermont Mut. Ins. Co." on Justia Law

Dozens of suits were filed against Irving Oil Limited (IOL) alleging environmental contamination by methyl tertiary butyl ether (MTBE) occurring from 1979 to the present. At the time of this opinion, all of the MTBE suits against IOL had been settled. In 2009, IOL filed a complaint asking the superior court to declare that ACE INA Insurance (ACE) had a duty to defend and indemnify in the MTBE suits. The superior court granted IOL’s motion for summary judgment in part and denied it in part, concluding that it could not declare that IOL was entitled a judgment on the duty-to-defend count as a matter of law. IOL appealed. The Supreme Court dismissed IOL’s appeal and ACE’s cross-appeal, holding that although a decision that an insurer does not have a duty to defend its insured is ordinarily immediately appealable under the death knell exception to the final judgment rule, the exception did not apply in this case because there were no MTBE cases pending against IOL.View "Irving Oil Ltd. et al. v. ACE INA Ins." on Justia Law

When Michael Lewis was sixteen years old, he was involved in a fatal car accident. At the time, Michael was driving a Ford pickup truck he had allegedly purchased from William Dodge. The other driver’s insurer paid Michael’s estate (Estate) its policy limit for liability. Michael’s mother, Angela, was insured by Concord General Mutual Insurance Company (Concord) at the time of the accident, and Michael’s father, David, was insured by Allstate Fire and Casualty Insurance Company (Allstate). The Concord and Allstate policies provided uninsured motorist (UM) benefits, as did Dodge’s policy with Property and Casualty Insurance Company of Hartford (Hartford). The Estate sought UM benefits from all three insurance companies. Each denied coverage, and the Estate filed suit against each company. The Superior court entered summary judgment in favor of Defendants. The Supreme Court vacated the judgment, holding that a genuine issue of material fact existed as to whether, pursuant to the agreement between Michael and Dodge, a final sale on the truck had been completed by the time of the accident. Remanded. View "Estate of Lewis v. Concord Gen. Mut. Ins. Co." on Justia Law