Justia Maine Supreme Court Opinion Summaries

Michael Nadeau, an employee with the Bureau of Insurance, married a manager of a Bureau-regulated entity. The Bureau subsequently discharged Nadeau on the basis that his continued employment at the Bureau while married to a manager of a Bureau-regulated entity violated Me. Rev. Stat. 24, 209(1). Nadeau initiated the grievance process manadated by the collective bargaining agreement (CBA). After an arbitration hearing, the arbitrator concluded that the Bureau violated the CBA by discharging Nadeau without just cause and ordered his reinstatement. The Bureau petitioned the superior court seeking to vacate the arbitration award, contending that the award of reinstatement required the Bureau to violate section 209(1), which prohibits the Bureau from employing persons "connected with the management" of Bureau-regulated entities. The superior court reported the case to the Supreme Court. The Court declined to answer the reported question regarding the interpretation of section 209 after finding that the arbitration award did not violate public policy, the arbitrator did not exceed his powers, and the award was not subject to further judicial scrutiny on that basis. Remanded for entry of a judgment confirming the arbitration award. View "Dep't of Prof'l & Fin. Regulation v. State Employees Ass'n" on Justia Law

Plaintiff began working for Defendant as a salesperson in 2005. Defendant resigned from his employment in 2010 and signed a separation agreement before his departure. Defendant initially paid Plaintiff pursuant to the separation agreement but then claimed it had paid Plaintiff more than it agreed to and stopped payment on two of the checks it had issued. Plaintiff filed a complaint against Defendant for breach of contract, breach of quasi-contract, and unjust enrichment. A federal jury found that Defendant had breached its separation agreement with Plaintiff and that Plaintiff was entitled to $70,331 in quantum meruit damages from Defendant. After the jury verdict, Plaintiff moved the federal court to conclude that the the quantum meruit damages were "wages" within the meaning of 26 Me. Rev. Stat. 626. The federal court then certified a question to the Maine Supreme Court, which answered by holding (1) whether a quantum meruit recovery activates the penalty provision of section 626 depends on the services rendered; (2) if the services rendered are of the type for which an employee would have been due wages, then application of section 626 to a recovery in quantum meruit is appropriate; and (3) if not, section 626 would not apply. View "Dinan v. Alpha Networks Inc." on Justia Law

Defendant was charged by a fifty-nine-count indictment that included forty-five counts of violation of privacy and one count of conspiracy to commit violation of privacy. Defendant subsequently filed a motion to dismiss the violation of privacy counts, which the trial court granted, concluding that based on the indictment and the State's offer of proof, the State could not prove the crimes as alleged. The State appealed, contending that the court erred in granting the motion because it was untimely and the indictment adequately charged the offenses pursuant to the applicable statutes. The Supreme Court affirmed, holding that because the relevant counts of the indictment, as augmented by the State's offer of proof, failed adequately to charge the offense of violation of privacy, the court properly granted Defendant's motion to dismiss. View "State v. Strong" on Justia Law

This was the second appeal of a matter involving six subdivision lot owners and their attempt to form a road association. In the first appeal, the Supreme Court held that the lot owners were authorized by statute to begin the process of forming the road association. On remand, the superior court issued an order requiring the parties to submit a proposed judgment. The resulting proposal asked the court to clarify what the word "majority" as used in 23 Me. Rev. Stat. Ann. 3101(5) meant. The court answered that the word "majority" as used in section 3101(5) required only a majority vote of those owners physically present at the meeting and those present by proxy and did not require a majority of all lot owners whether present or not. The Supreme Court affirmed, holding that the superior court did not err in declaring that "a majority vote" as used in section 3101(5) meant a majority vote of lot owners actually present or represented by proxy at a properly called road association meeting. View "Goudreau v. Pine Springs Rd. & Water, LLC" on Justia Law

The Department of Health and Human Services filed petitions seeking the appointment of a public guardian and conservator for Helen F. After a hearing, the county probate court adjudicated Helen to be incapacitated and appointed the Department as Helen's public guardian and conservator. Helen appealed. The Supreme Court vacated the judgment, holding (1) Helen's case was before the Court without any acceptable record of the proceedings below; and (2) the trial court's inability to remember Helen's case, and Helen's corresponding inability to provide an adequate statement of the evidence was no fault of Helen's. Remanded for a de novo adjudication of Helen's capacity. View "In re Guardianship of Helen F." on Justia Law

Plaintiff, an owner of a condominium unit, filed a complaint, individually and derivatively on behalf of the condominium association (Association), against the Association and four members of its board of directors (Board), claiming that Defendants had refused effectively to enforce the condominium's smoking ban. The business and consumer docket dismissed the counts of the complaint related to the smoking ban for failure to state a claim. The Supreme Court affirmed, holding that the court did not err in (1) finding that Plaintiff did not have a right to bring a shareholder derivative action under either the Maine Condominium Act or the Maine Nonprofit Corporation Act; (2) dismissing Plaintiff's individual claims related to the smoking ban; and (3) denying Plaintiff's motion to file a second amended complaint following the partial dismissal of his amended complaint. View "America v. Sunspray Condo. Ass'n" on Justia Law

Bank brought an action against Defendant for foreclosure on a residential mortgage. In this case, Bank was a holder entitled to enforce the mortgage note and currently had possession of the note, which was endorsed in blank, and therefore had the power to enforce the note. After mediation, Bank moved for summary judgment. Before acting on the motion, the superior court reported a question to the Supreme Court, which the Court accepted. The question was: "What is the proof that is required for a party to prove 'ownership' of the mortgage note and mortgage for purposes of foreclosure?" The Supreme Court held that a plaintiff in a foreclosure action must identify the owner or economic beneficiary of the note and provide certain other evidence as described in 14 Me. Rev. Stat. 6321. View "Bank of Am., N.A. v. Cloutier" on Justia Law

Defendant and two co-conspirators pleaded no contest or guilty to various charges. Defendant pleaded guilty to two counts of intentional or knowing murder. The sentencing court sentenced Defendant to two concurrent terms of forty-five years in prison. Defendant appealed, arguing that the court abused its discretion in sentencing him to a longer prison term than that of his two co-conspirators. The Supreme Court affirmed the sentences, holding that, given the court's consideration of the purposes of sentencing, proper completion of the two-step sentencing procedure for murder, articulation of the reasons for the sentence, and explicit discussion of and adjustment for the sentencing inequality at issue, the sentencing court did not abuse its discretion in sentencing Defendant. View "State v. Hamel" on Justia Law

In 2010, Hebron Academy requested a tax abatement from the Town for the 2009 tax year. Because the Academy did not file the abatement request before the statutory deadline, the Town denied the request. The Board of Assessment Review denied the request on the same ground. The Academy subsequently filed a complaint seeking a declaratory judgment that its properties were exempt from taxation and that the Town must reimburse it for real estate taxes it paid on its exempt properties for the prior three years. The superior court declared that the Academy was entitled to the exemption for most of its property but that res judicata precluded the court from relieving it of its obligation to pay the 2009 taxes at issue. The Supreme Court affirmed, holding (1) Hebron Academy, as a literary and scientific institution, was entitled to a tax exemption for its real estate "owned and occupied or used solely for [its] own purpose"; and (2) the trial court correctly concluded that res judicata precluded the declaratory judgment from applying to the 2009 tax year because an administrative adjudication had been rendered on the merits of the case. View "Hebron Academy, Inc. v. Town of Hebron" on Justia Law

Plaintiff filed an action in the U.S. district court against a Maine police officer, alleging that the officer used force in arresting Plaintiff in violation of state and federal law. A jury found the officer liable on Plaintiff's state law negligence claim and awarded Plaintiff $125,000 in damages. The district court amended the judgment to reduce the damages award to $10,000 pursuant to Me. Rev. Stat. 14, 8104-D. Plaintiff appealed to the First Circuit Court of Appeals. The First Circuit certified two questions for the Supreme Court's review. The Court answered only the first question by holding that whether or not an insurance policy is available to cover a judgment against a government employee sued in his personal capacity, the applicable limit on the award of damages is $10,000 pursuant to section 8104-D rather than $400,000 or the policy limit pursuant to Me. Rev. Stat. 14, 8105(1) and 8116. View "Fortin v. Titcomb" on Justia Law