Justia Maine Supreme Court Opinion Summaries

Appellant, a former corrections officer, was dismissed after an administrative hearing on November 4, 2009. On November 18, the commissioners issued their written decision which containted their findings and rationale. On December 18, the appellant filed a compliant asserting a due process claim pursuant to 42 U.S.C. 1983 and a wrongful termination claim pursuant to 30-A M.R.S. 501(3)(A). At issue was what constitutes ânotice of any actionâ to trigger M.R. Civ. P. 80B(b)âs 30-day time limit for filing an administrative appeal. The Supreme Court vacated and remanded the lower courtâs dismissal of appellantâs due process and wrongful termination claims as untimely, holding that Rule 80B(b)âs time limit for seeking review of a decision to dismiss an employee does not commence until the employee receives a written decision of the county commissioners or personnel board. The Court also held that because appellant did not have an opportunity to address his suspension before he was terminated, direct review pursuant to Rule 80B(b) would not provide an adequate remedy for appellantâs Section 1983 claim; therefore, denial of appellantâs right to due process of law was independent of his administrative appeal.

Sisters of Charity Health System, Inc. (SOCHS) sued its former employees, Douglas Farrago, MD, Raymond Stone, DO and Carolyn Kase, DO, to enforce restrictive covenants contained in contractual agreements between the doctors and SOCHS. The Superior Court entered a judgment in favor of SOCHS and ordered each doctor to pay liquidated damages pursuant to clauses in their contracts. On appeal, the doctors contended that the restrictive covenants and liquidated damages clauses were unenforceable. The Supreme Court's focus on appeal was whether the covenants reasonably sought to protect a legitimate business of SOCHS. The Court concluded that the covenants did protect legitimate business interests, and the contracts contained enforceable liquidated damages provisions. The Court affirmed the decision of the Superior Court in favor of SOCHS.