Justia Maine Supreme Court Opinion Summaries

John and Jane Doe, the parents Susan Doe, a transgender girl, filed a complaint with the Maine Human Rights Commission alleging that Regional School Unit 26 (RSU 26) had violated the Maine Human Rights Act (MHRA) by excluding Susan from the communal girls’ bathroom at elementary and middle school. The Commission found reasonable grounds to believe discrimination had occurred. Thereafter, the Does and the Commission filed a complaint in the superior court asserting claims for unlawful discrimination in education (Count I) and unlawful discrimination in a place of public accommodation (Count II) on the basis of sexual orientation. The superior court granted RSU 26’s motion for summary judgment on all counts. The Supreme Court vacated the judgment of the superior court, holding that where it has been clearly established that a student’s psychological well-being and educational success depend on being permitted to use the communal bathroom consistent with her gender identity, denying the student access to the appropriate bathroom constitutes sexual orientation discrimination in violation of the MHRA. Remanded for entry of summary judgment for the Does and the Commission. View "Doe v. Reg'l Sch. Unit 26" on Justia Law

In 1993, Gloria Hall executed a will that devised all personal and real property to her husband. In 2002, Gloria’s husband filed for divorce. In 2004, Gloria devised a new will which revoked all earlier wills and which devised nothing to her husband. The probate and family court later appointed a temporary guardian for Gloria due to her dementia. In 2007, the temporary guardian signed a separation agreement with Gloria’s husband that stated that neither Gloria nor her husband would modify the wills each had executed in 1993. After Gloria died, the county probate court concluded that the 2004 will could not have been revoked by the agreement entered into by the temporary guardian and admitted the 2004 will to probate. The Supreme Court affirmed, holding that the probate court did not err in admitting Gloria’s 2004 will to probate because (1) the parties stipulated that the 2004 was validly executed by a person with testamentary capacity, and the will was not shown to be the subject of undue influence; and (2) the will could not be revoked by the separation agreement because the agreement itself failed to comply with the plain terms of the statute governing will revocation. View "Estate of Hall" on Justia Law

After a jury trial, Appellant was convicted of escape and for assaulting a corrections officer in a courtroom and then fleeing from the courtroom before being captured while attempting to flee from the courthouse. On appeal, Appellant argued, among other things, that the State failed to prove he successfully exited the courthouse after fleeing the courtroom, a finding Appellant claimed was necessary to support his conviction for escape. The Supreme Court affirmed the judgment, holding that the evidence was sufficient to support (1) a finding that Appellant was in custody pursuant to a court order, as was required to support each conviction; and (2) a finding that Appellant left official custody without official permission, which was sufficient to support the escape conviction. View "State v. Troy" on Justia Law

Plaintiff was a public assistance recipient who was accepted to rent an apartment owned by RRE Coach Lantern Holdings, LLC. Plaintiff’s caseworker indicated that Coach Lantern would have to include a Housing and Urban Development (HUD) tenancy addendum in Plaintiff’s lease for Plaintiff to be able to use her voucher for subsidized rent. Coach Lantern refused to include the addendum in Plaintiff’s lease. Because Plaintiff could not use the voucher unless Coach Lantern included the addendum in her lease, Plaintiff did not rent the apartment. Plaintiff subsequently filed a complaint with the Maine Human Rights Commission alleging that Coach Lantern’s policy of refusing to include the HUD tenancy addendum in her lease constituted a refusal to participate in the voucher program, which amounted to discrimination against Plaintiff on the basis of her status as a public assistance recipient in violation of the Maine Human Rights Act (MHRA). The superior court entered summary judgment in favor of Coach Lantern. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Coach Lantern because the undisputed facts showed that Coach Lantern did not discriminate against Plaintiff in violation of the MHRA. View "Dussault v. RRE Coach Lantern Holdings, LLC" on Justia Law

Darling’s, a Ford dealer and franchisee, filed a complaint before the Maine Motor Vehicle Franchise Board (Board), alleging that Ford Motor Company, an automobile manufacturer and franchisor, violated the Business Practices between Motor Vehicle Manufacturers, Distributors and Dealers Act (Dealers Act). The Board concluded that Ford violated the Dealers Act by terminating an incentive program without providing Darling’s with written notice by certified mail. The superior court affirmed the Board’s factual findings and the Board’s damages award. The Supreme Court affirmed in all respects but one, holding that the Dealers Act does not authorize the Board to award monetary damages. Remanded for a determination of damages by a jury. View "Ford Motor Co. v. Darling's" on Justia Law

Plaintiff was a Maine-based law firm with affiliated law offices in other states. In an effort to determine the proper Maine income tax treatment for distributions to its New Hampshire partners, Plaintiff filed a Freedom of Access Act (Act) request with the Maine Revenue Service and the State Tax Assessor, ultimately seeking all allocation and apportionment formulas, methodologies, or calculations applicable to the determination of Maine income tax for nonresident partners in a partnership. The Revenue Service filed for in camera review of seven documents. After reviewing the documents in camera, the superior court determined that the documents were confidential and thus not subject to redaction or disclosure. The Supreme Court affirmed, holding that the documents that were covered by Plaintiff’s request for information consisted entirely of information deemed confidential pursuant to Me. Rev. Stat. Ann. 36, 191(1), which excepts certain tax information and records from the definition of public records pursuant to the Act. View "Preti Flaherty Beliveau & Pachios LLP v. State Tax Assessor" on Justia Law

The district court entered a divorce judgment awarding shared primary residence of Larry Nadeau and Jessica Potila’s minor children, determining child support, and allocating the dependent income tax exemptions. Nadeau appealed and Potila cross-appealed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in awarding shared primary residence; (2) did not abuse its discretion in denying Nadeau a deviation from the child support guidelines; and (3) did not err in finding that Potila failed to meet her burden of proving that a portion of the value of the marital residence, owned by Nadeau prior to the marriage, was marital. View "Potila v. Nadeau" on Justia Law

Plaintiff and Defendant each held a one-third interest in property as tenants in common. Plaintiff and Defendant, assisted by counsel, had discussions via email regarding the possible sale of Plaintiff’s interest. The emails stated that Defendant “offered” to acquire Plaintiff’s interest and that Plaintiff “accept[ed]” the offer. Plaintiff subsequently filed a complaint against Defendant seeking, among other things, specific performance of the contract for the sale of his interest in the property to Defendant. The superior court granted partial summary judgment on the specific performance claim, concluding there had been no valid contract formation because the emails between Plaintiff and Defendant did not contain all the material terms necessary to form a contract for the sale of land. The Supreme Court vacated and remanded, holding (1) an email can constitute a writing pursuant to the statute of frauds and the Maine Uniform Electronic Transactions Act; and (2) unresolved issues of material fact existed as to whether a contract for the sale of land was formed in this case. View "McClare v. Rocha" on Justia Law

Mother and Father were married and had a son. After Father was convicted of sexual abuse of girls who had been his piano students, Mother filed for a divorce. The trial court granted the parties a divorce, concluded that Father’s criminal conduct constituted financial misconduct, and divided the parties’ property. The Supreme Court affirmed, holding that the trial court (1) provided findings necessary to support its judgment; (2) did not err as a matter of law in considering Father’s criminal conduct as a relevant factor in arriving at a just division of the parties’ marital estate; and (3) equitably divided the marital property. View "Lesko v. Stanislaw " 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