Justia Maine Supreme Court Opinion Summaries

During her employment with Employer, Appellant applied to open a registered medical marijuana dispensary. Appellant was later terminated from her employment. Appellant filed a complaint against Employer, alleging in count I of her complaint that her termination was a violation of the Maine Medical Use of Marijuana Act (Act). Appellant argued that her application for a license to operate a medical marijuana dispensary was authorized conduct within the meaning of the Act and her subsequent termination was thus a penalty prohibited by the Act. The superior court granted Employer's motion to dismiss with respect to several counts, including count I. The parties later stipulated to the dismissal of the remaining counts. The Supreme Court affirmed, holding that the Act does not create a private right of action against private employers, but rather, protects against prosecution and penalties by governmental regulatory entities. View "Savage v. Me. Pretrial Servs., Inc." on Justia Law

Employee filed this action against Employer and her four individual supervisors (Supervisors), claiming whistleblower discrimination pursuant to the Whistleblowers' Protection Act (WPA) and the Maine Human Rights Act (MHRA) and sex discrimination pursuant to the MHRA. The superior court granted Supervisors' motion to dismiss, finding they could not be held individually liable pursuant to the WPA and the MHRA. The court then entered summary judgment in favor of Employer on all claims. Employee appealed, contending (1) summary judgment for Employer was improper because she presented a prima facie case of whistleblower discrimination and there remained material facts in dispute, and (2) the dismissal of her claims against Supervisors was improper. The Supreme Court affirmed with respect to the sex discrimination claim and the dismissal of Supervisors but vacated the judgment with respect to the whistleblower discrimination claim against Employer, holding (1) material facts remained in dispute regarding Employee's whistleblower claim; but (2) the WPA and MHRA do not provide for individual supervisor liability. View "Fuhrmann v. Staples the Office Superstore E., Inc." on Justia Law

Brockway-Smith Company and MMTA Workers' Compensation Trust appealed from a decision of a Workers' Compensation Board hearing officer awarding incapacity benefits to Richard Graves for a 2003 work-related injury to his left shoulder. Brockway-Smith contended that Graves's claim for the 2003 injury was barred for failure to file it within the six-year limitations period in 39-A Me. Rev. Stat. The Supreme Court was asked to decide whether that six-year period was tolled until the employer filed a first report of injury with the Workers' Compensation Board, even though at the time of the injury the employer was not required to file a first report pursuant to 39-A Me. Rev. Stat, 303. The Supreme Court affirmed the hearing officer's decision, holding that the limitations period did not begin to run until the first report was filed. View "Graves v. Brockway-Smith Co." on Justia Law

Norman Budge and twenty-eight additional parties (collectively, Employees) filed a complaint for review of government action for the Town of Millinocket's (Town) amendments to its personnel policy originally adopted as a town ordinance. In the most recent amendment, the Town reduced its obligation for paying for the health insurance plan for its employees and established a new policy for the health insurance offered to retirees that resulted in the Town reducing its payment of the retirees' premiums. Employees alleged that, regardless of the policy language, this reduction was inconsistent with promises made to them either when they were hired or during their tenure with the Town. The superior court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the personnel policy did not create an enforceable contract between the Town and its employees; (2) the Town was not bound to pay Employees' retirement group hospitalization and life insurance premiums by virtue of promissory estoppel; and (3) the Town's reduction in benefits did not result in an unconstitutional taking. View "Budge v. Town of Millinocket" on Justia Law

Plaintiff filed a complaint against her former employer, Adroscoggin County, alleging gender discrimination, constructive discharge, and retaliation. The superior court granted partial summary judgment in favor of the County dismissing the counts of constructive discharge and gender discrimination. The retaliation claim proceeded to trial, and the jury returned a verdict for the County. Plaintiff subsequently appealed from the partial summary judgment dismissing the constructive discharge claim. The Supreme Court affirmed, holding (1) notwithstanding its application in the labor and discrimination contexts, constructive discharge does not exist as an independent cause of action under Maine statutory or common law; and (2) because Plaintiff did not challenge the summary judgment denying her claim for gender discrimination or the judgment entered on the jury's verdict denying her claim for retaliatory discrimination, nor did Plaintiff allege that the actions giving rise to her alleged constructive discharge from employment were themselves a form of unlawful discrimination under the Maine Human Rights Act, Plaintiff's claim for constructive discharge failed. View "Levesque v. Androscoggin County" on Justia Law

The issue before the Supreme Court in this case was whether a resort violated the requirement to pay its employees the minimum wage when it paid wait staff a portion of the standard "service charge" that it added to its banquet customers' bills and treated that portion as a "tip" that satisfied the minimum wage law by qualifying the resort for a tip credit. Allison Hayden-Tidd appealed the superior court's grant of summary judgment to The Cliff House & Motels, Inc. and the denial of her cross-motion for summary judgment. On appeal, Hayden-Tidd contended that the court erred when it rejected her argument that the wage laws required Cliff House to treat its entire banquet staff service charge as a "tip" to be paid to the banquet servers for purposes of the tip credit statute. The Supreme Court agreed that Cliff House's compensation arrangement with its banquet servers did not violate the tip credit statute, and therefore was not a violation of the minimum wage law. View "Hayden-Tidd v. Cliff House & Motels, Inc." on Justia Law

William Buckley appealed a decision of a Workers' Compensation Board hearing officer on remand from the Supreme Court. Buckley contended that, when determining whether his permanent impairment level was above the threshold for receiving partial incapacity benefits for the duration of his incapacity, the hearing officer misinterpreted the Court's mandate by failing to combine or "stack" the percentages of permanent impairment attributable to all of his work injuries. Furthermore, Buckley asserted that the hearing officer's finding that he suffered 0% permanent impairment from a 2001 injury is inconsistent with a finding in the prior decree that he suffered 7% permanent impairment for that injury. Upon review, the Supreme Court found no error and affirmed the hearing officer's decision. View "Buckley v. S.D. Warren Co." on Justia Law

Maine Public Employees Retirement System (the System) appealed a superior court judgment reversing a decision of the System’s Board of Trustees that denied Petitioner Ellen Goodrich basic life insurance coverage under the group life insurance plan administered by the System. Upon review of the record, the Supreme Court vacated the Superior Court's judgment in part and remanded the case for entry of a judgment: (1) vacating the decision of the Board; and (2) remanding to the Board with instructions to provide Goodrich with prospective basic life insurance coverage after she paid back premiums accrued to date. View "Goodrich v. Maine Public Employees Retirement System" on Justia Law

Appellant Timothy Daniels appealed a superior court's grant of summary judgment in favor of Defendants Narraguagus Bay Health Care Facility and North Country Associates, Inc. Appellant contended that the court erred in concluding that Narraguagus and North Country were entitled to judgment as a matter of law on his disability discrimination and retaliation claims made pursuant to Maine's Human Rights Act. Appellant suffered a work-related injury to his right shoulder in 2007 and thereafter was given work restrictions by his physician that prevented him from performing all of the work duties he had previously handled. In 2008, Appellant underwent surgery and then began a leave of absence. A few months later, Appellant notified his employer that he was applying for more leave at her insistence. In that letter, Appellant also reported that he had been cleared for light duty work, accused his supervisor of refusing to accommodate his disability, and asked for light duty work. No work was afforded to Appellant as a result of that letter. Appellant suffered another work-related injury to his right shoulder in 2009, and, although he did not lose any time from work as a result of that injury, he was restricted to modified duty for the next three months. During that period Appellant was disciplined for performance issues. Early in November 2009, when Daniels no longer had any work restrictions, a new Narraguagus administrator gave Appellant a performance improvement plan for failing to complete some tasks at all and failing to complete other tasks on time. In November, 2009, in response to the complaint that he filed in 2008, the Commission issued Appellant a right-to-sue letter pursuant to the Human Rights Act. When state regulators visited Narraguagus to conduct a licensing inspection, they uncovered issues that resulted in fines to the facility. Narraguagus blamed Appellant for the negative inspection and terminated his employment on January 29, 2010. After his termination, Appellant filed a two-count complaint against Narraguagus and North Country. On appeal, Appellant advanced two theories of liability against North Country: (1) that it can be liable because it is part of an integrated enterprise with Narraguagus, and (2) that it acted in Narraguagus’s interest in discriminating against him. Finding multiple issues of disputed facts regarding North Country's involvement in the actions that Appellant claimed constituted discrimination and retaliation, the Supreme Court vacated the grant of summary judgment in favor of Defendants, and remanded the case for further proceedings. View "Daniels v. Narraguagus Bay Health Care Facility" on Justia Law

Michael Joyce, who was frequently exposed to airborne asbestos while working, died of lung cancer. His last documented exposure to asbestos dust was while working for Commercial Welding. A Workers' Compensation Board hearing officer later awarded the estate of Joyce benefits on a petition for an award of compensation and ordered benefits paid to Mary Joyce, Michael's widow, on a petition for death benefits. Commercial Welding appealed the hearing officer's decision as well as the hearing officer's determinations that (1) it had not cured a previously established violation of the Board's "fourteen-day-rule" because it had not paid interest on the required payment imposed for the violation, and (2) it was not permitted to offset the amount of the death benefits ordered to be paid to Mary by the amount of the payment for the fourteen-day rule violation. The Supreme Court vacated in part and affirmed in part the hearing officer's decision. The Court (1) disagreed with the hearing officer's decision that interest was due on the required payment to the Estate, but (2) agreed that the required payment amount could not be used to offset the death benefits ordered to be paid to Mary. View "Estate of Joyce v. Commercial Welding Co." on Justia Law