Justia Maine Supreme Court Opinion Summaries

Plaintiff filed an application for disability retirement benefits alleging that she was unable to perform her job with the Maine Department of Transportation because of her numerous disabilities. The Maine Public Employees Retirement System Board of Trustees denied benefits after considering Plaintiff’s medical records. Plaintiff appealed, challenging only the denial of benefits as to her fibromyalgia. The Supreme Judicial Court affirmed, holding (1) the medical board’s reports were a proper part of the evidentiary record; and (2) the record did not compel a finding that Plaintiff met her burden of proving that her fibromyalgia caused functional limitations that made it impossible for her to do her job. View "Behr v. Maine Pub. Employees Ret. Sys." on Justia Law

Brenda Freeman was injured in a work-related accident in 2007. Freeman returned to work but in a lower-paying position. Because of the decrease in her wages, Freeman received partial incapacity benefit payments. In 2011, Freeman suffered a second work-related injury. During Freeman’s period of incapacity, her employer paid 100 percent partial incapacity benefits based on the 2007 injury. Freeman filed a petition for award of compensation claiming that although she was already receiving benefits that equaled the maximum compensation rate as a result of her 2007 injury, she was eligible for additional compensation for the same period as a result of her 2011 injury. The hearing officer concluded that Freeman was ineligible for compensation beyond the statutory maximum benefit, regardless of the number of injuries. The Workers’ Compensation Board Appellate Division affirmed. The Supreme Judicial Court affirmed, holding that the hearing officer correctly construed the statutory maximum benefit provision of the Workers Compensation Act as a total ceiling on the potential benefits available to an injured employee, regardless of the number of injuries the employee suffers. View "Freeman v. NewPage Corp." on Justia Law

A Deputy of the Department of Labor, Bureau of Unemployment Compensation determined that Plaintiff had been overpaid $13,157 in unemployment insurance benefits and was required to reimburse the Bureau in that amount. Nearly one year after the expiration of the appeal period Plaintiff appealed the Department’s decision. The Department of Labor, Division of Administrative Hearings dismissed the appeal as untimely. On appeal, the Unemployment Insurance Commission remanded the matter to the Division to develop an evidentiary record on the timeliness of Plaintiff’s appeal and the merits of her appeal. On remand, the Division developed the record and submitted the record to the Commission for decision. The Commission concluded that Plaintiff’s appeal to the Division was untimely. The superior court affirmed. The Supreme Judicial Court affirmed, holding that the Commissioner correctly concluded that the Deputy’s decision had become final and that it was without jurisdiction to address the merits of her untimely appeal. View "Ramelli v. Unemployment Ins. Comm’n" on Justia Law

After Plaintiff was discharged from her employment at a nursing home owned by Defendant, Plaintiff commenced this action alleging that Defendant violated the Maine Whistleblowers’ Protection Act (WPA) by terminating her because she had made complaints about staffing and patient safety. The superior court granted summary judgment in favor of Defendant. The Supreme Judicial Court vacated the judgment, holding (1) the record was sufficient to allow a jury to reasonably find that Plaintiff’s complaints constituted a protected activity under the WPA and that the adverse employment action was substantially motivated at least in part by retaliatory intent; and (2) accordingly, Plaintiff presented a prima facie case of unlawful retaliation. View "Cormier v. Genesis Healthcare LLC" on Justia Law

Gerard Brady brought a claim against Cumberland County for employment retaliation pursuant to the Maine Whistleblowers’ Protection Act (WPA), alleging that disciplinary action taken against him by the County was motivated by complaints he made about the investigation of an incident at the Cumberland County jail. The trial court granted summary judgment in favor of the County on Brady’s WPA claim, concluding that Brady failed to present a prima facie case of retaliation. The Supreme Court vacated the judgment, holding (1) Brady produced sufficient evidence to allow a jury to find that the adverse employment action taken against Brady was substantially motivated at least in part by retaliatory intent; and (2) the application of the compartmentalized three-step process set out in McDonnell Douglas Corp. v. Green to the summary judgment stage of WPA retaliation cases is not appropriate. View "Brady v. Cumberland County" on Justia Law

In 2009, John Flynn joined the law firm of Daniel G. Lilley Law Office, P.A. (LLO). In 2011, Flynn left LLO to open his own practice. LLO and Daniel Lilley subsequently filed a complaint against Flynn seeking a judicial declaration that any contingency fees earned in cases that Flynn brought to LLO were the property of LLO to be distributed at Lilley’s sole discretion and seeking the return of such fees that Flynn had already received. Flynn counterclaimed. In 2012, the superior court denied LLO’s motion to consolidate this case with the closely-related cases at issue in Tucker v. Lilley. After a jury trial, the superior court entered judgment awarding Flynn unpaid salary from his tenure at LLO and apportioned attorney fees between the parties in cases that Flynn brought to LLO from his former law firm. The Supreme Court vacated the judgment, holding that the superior court abused its discretion in declining to consolidate this case with the cases at issue in Tucker v. Lilley, as this case was an integral member of the set of cases that “must be resolved in one consolidated action before a single fact-finder.” Remanded with instructions to grant LLO’s motion to consolidate. View "Daniel G. Lilley Law Office, P.A. v. Flynn" on Justia Law

The Workers’ Compensation Board imposed a $30,000 penalty on Nale Holyoke and his construction company (collectively, Holyoke) for violating the insurance coverage requirements of the Workers’ Compensation Act (WCA). The Workers’ Compensation Board Appellate Division vacated the Board’s imposition of penalties on Holyoke. The Supreme Judicial Court affirmed, albeit for a different reason than that expressed by the Appellate Division, holding that Holyoke complied with Me. Rev. Stat. 39-A, 401 and 403 by maintaining workers’ compensation policies that would have provided compensation to any worker entitled to benefits, and therefore, Holyoke complied with the coverage requirements of the WCA. View "Workers Comp. Bd. Abuse Investigation Unit v. Nate Holyoke Builders, Inc." on Justia Law

Plaintiff was injured while working at a paper mill. Plaintiff hired Defendant, an attorney, to represent her in her workers’ compensation claim. The Workers’ Compensation Board awarded Plaintiff, still represented by Defendant, partial incapacity benefits. Plaintiff later settled with her employer. Plaintiff subsequently filed a complaint against Defendant, alleging that, due to Defendant’s failure to exercise due care and negligence, she was awarded partial incapacity benefits rather than total incapacity benefits. The superior court granted summary judgment in favor of Defendant. The Supreme Judicial Court affirmed, holding that summary judgment was correctly granted where the jury could not assess damages without resorting to speculation. View "Allen v. McCann" on Justia Law

Plaintiff, a former employee at the Maine Bureau of Insurance, an agency within the Department of Professional and Financial Regulation (Department), sued the Department, alleging that she was fired in violation of the Maine Human Rights Act (MHRA) and the Maine Whistleblowers’ Protection Act (WPA). The superior court entered judgment in favor of the Department. The Supreme Judicial Court affirmed, holding (1) the superior court did not err in granting summary judgment to the Department on the ground that Plaintiff did not engage in activity protected by the WPA; and (2) therefore, the Court need not address Plaintiff’s arguments on pretext or adverse employment action. View "Galouch v. Dep’t of Prof’l and Fin. Regulation" on Justia Law

In 2010, Gregory Sullwold died of a heart attack while exercising on a treadmill in his home. Sullwood was employed by the Salvation Army at the time of his death, and the Salvation Army permitted Sullwold to work remotely from home. In 2011, Sullwold’s widow filed a petition for award of compensation, alleging that Sullwold’s work resulted in his heart attack. The Workers’ Compensation Board granted the petition. A hearing officer reaffirmed the original order, finding that work stress was a major factor in Sullwold’s death. The Supreme Court affirmed, holding that the hearing officer (1) did not err in finding that the evidence triggered the presumption found in 39-A Me. Rev. Stat. 327, which provides that an employee covered by the Maine Workers’ Compensation Act must be paid compensation if he or she receives a personal injury arising out of and in the course of employment; and (2) did not erroneously shift the burden of persuasion to the Salvation Army in this case. View "Sullwold v. Salvation Army" on Justia Law