Justia Maine Supreme Court Opinion Summaries

Michael Bryant, an owner and employee of Prime Cut Meat Market, assaulted another motorist, Francis Latanowich, in an apparent incident of road rage. Prime Cut and its employees were insured by a policy issued by The Travelers Indemnity Company. Latanowich and his wife sued Bryant and Prime Cut. Prime Cut successfully moved for summary judgment, and Bryant and the Latanowiches agreed to a settlement that included Bryant assigning all of his rights related to potential insurance coverage to the Latanowiches. Travelers later filed a complaint against Bryant and the Latanowiches seeking a declaratory judgment that it had no duty to indemnify Bryant for claims arising from the altercation because Bryant was not an insured under its policy issued to Prime Cut for purposes of that conduct. The superior court concluded that the policy language did not cover the incident, and it granted Travelers's motion for summary judgment. The Latanowiches appealed. The Supreme Court affirmed, holding that, pursuant to the unambiguous language of the policy, the court correctly concluded that Bryant's assault of Latanowich was not covered by the policy and properly entered summary judgment. View "Travelers Indem. Co. v. Bryant" on Justia Law

Defendant Frank Johnson was convicted for operating after habitual offender revocation. Johnson appealed, arguing that the superior court erred in denying his motion to strike an earlier conviction offered by the State to enhance his current charge to a Class C crime because the prior conviction resulted from a guilty plea that was allegedly constitutionally flawed. At issue was whether Johnson had the right to collaterally attack the prior conviction. The Supreme Court affirmed after examining relevant federal and state precedent, holding (1) a criminal defendant may not collaterally attack a prior conviction during proceedings related to a different offense unless the defendant alleges a violation of the Sixth Amendment right to counsel; and (2) because Johnson did not assert a violation of his Sixth Amendment right to counsel as the basis for his collateral attack on his prior conviction, his motion to strike was properly denied without further hearing. View "State v. Johnson" on Justia Law

Defendant William Hanaman was convicted of intentional or knowing murder following a jury trial. Hanaman appealed, contending that the trial court erred in refusing to instruct the jury on the affirmative defense of adequate provocation to reduce the murder charge to manslaughter pursuant to Me. Rev. Stat. 17-A, 201(3). The trial court determined that an adequate provocation instruction was subsumed by instructions that were given on self-defense and imperfect self-defense. The Supreme Court affirmed, holding that the evidence was not legally sufficient to support a jury instruction on the affirmative defense of adequate provocation, and therefore, the court did not err in refusing to give an adequate provocation instruction in this case. View "State v. Hanaman" on Justia Law

Employee suffered a work-related stroke, after which the Workers' Compensation Board awarded Employee 800 weeks of total incapacity benefits for the permanent and total loss of industrial use of one leg and one arm. After paying total incapacity benefits for the 800-week period, Employer filed petitions for review and for determination of offset rights. A Board hearing officer granted Employer's petitions and determined that because Employee had received 800 weeks of permanent incapacity benefits pursuant to the conclusively presumptive time period established in Me. Rev. Stat. 39-A, 212(2)(G), Employer could prospectively take statutory offsets against Employee's benefits pursuant to Me. Rev. Stat. 39-A, 221. The Supreme Court affirmed, holding that although Employee remained totally incapacitated from work, after 800 weeks, Employer was entitled to reduce the total benefit by amounts authorized by Me. Rev. Stat. 39-A, 221. View "Mitton v. Verizon" on Justia Law

Maine School Administrative District 61 (MSAD 61) contracted with International WoodFuels for the installation of a heating system at a school owned by MSAD 61. Woodfuels contracted with Thayer Corporation to assemble and install the boiler. Thayer provided the materials and performed the work as required under the contract, but WoodFuels failed to make payments to Thayer. Thayer timely recorded a mechanic's lien against the school for the materials and services it provided to WoodFuels and subsquently filed an action to enforce the lien against WoodFuels and MSAD 61. The superior court granted MSAD 61's cross-motion for summary judgment and denied Thayer's motion for summary judgment with respect to the lien action, concluding that Thayer's services were not lienable pursuant to the mechanic's lien statute. The Supreme Court affirmed, holding that the superior court did not err in concluding that WoodFuels's heating system was not intended to become a permanent part of the school's property and was therefore not lienable by Thayer. View "Thayer Corp. v. Me. Sch. Admin. Dist. 61" on Justia Law

The Land Use Regulation Commission (LURC) and Plum Creek Timberlands, LLC and Plum Creek Land Company (collectively, Plum Creek) appealed from a judgment entered in the business and consumer docket vacating LURC's approval of a rezoning petition and concept plan submitted by Plum Creek for land it owned in the Moosehead Lake region. LURC and Plum Creek contended that the court erred by concluding that LURC violated its procedural rules by failing to hold an additional evidentiary hearing on amendments to Plum Creek's petition. Forest Ecology Network, RESTORE: The North Woods, and the Natural Resources Council of Maine cross-appealed, arguing primarily that LURC erred in approving the petition because several aspects of the concept plan conflicted with statutory requirements. The Nature Conservancy and Forest Society of Maine intervened. The Supreme Court vacated the judgment and remanded for the entry of a judgment affirming LURC's decision, holding that LURC did not violate its procedural rules and did not otherwise err by approving the rezoning petition and concept plan. View "Forest Ecology Network v. Land Use Regulation Comm'n" on Justia Law

Wells Fargo Bank, NA (the Bank) filed a complaint for foreclosure against David and Lee Anne deBree, alleging that the deBrees were in default of a mortgage note owned by the Bank. The complaint also alleged that the Bank was a successor by merger to Wells Fargo Home Mortgage, Inc. The deBrees denied they were in default and denied the allegation that the Bank was successor to Wells Fargo Home Mortgage, Inc. The district court granted summary judgment in favor of the Bank. At issue on appeal was an affidavit submitted by the Bank in favor of its motion that showed the rights on the note and mortgage were transferred not to Wells Fargo Bank, NA, but rather to Wells Fargo Home Mortgage, Inc. The Supreme Court vacated the summary judgment and remanded, holding that the Bank failed to offer evidence that it owned the deBrees' mortgage and note, and therefore, it failed to demonstrate that there were no genuine issues of material fact and that it was entitled to judgment as a matter of law. View "Wells Fargo Bank, NA v. deBree" on Justia Law

Victor Bravo Aviation, LLC purchased an aircraft in Connecticut in 2004 that was flown to Victor Bravo in Connecticut. Victor Bravo did not register the aircraft in Maine but used it regularly in Maine during the first twelve months of ownership. In 2007, the State Tax Assessor assessed Victor Bravo a use tax on its aircraft plus interest, penalties and costs. Victor Bravo appealed. The Business and Consumer Docket entered summary judgment for the Assessor affirming the assessment of the tax and interest, and judgment for Victor Bravo waiving and abating the non-payment penalty. The Supreme Court affirmed except vacated and remanded the issue of interest waiver or abatement. On remand, the court declined to waive or abate the interest as of the date of the reconsideration decision. Victor Bravo appealed. The Supreme Court affirmed, holding that the court properly considered Victor Bravo's arguments for failure to pay the use tax and deemed them unsatisfactory to warrant a waiver or abatement of interest under the statutory scheme. View "Victor Bravo Aviation, LLC v. State Tax Assessor" on Justia Law

Lewis Hatch signed a promissory note to an institution later renamed to The Bank of Maine. Although Lewis alone signed the note, both Lewis and Kathleen Hatch secured it by mortgaging undeveloped land. The Bank subsequently filed a foreclosure complaint, and later filed a motion for summary judgment. In support of its motion, the Bank relied on an affidavit of its own employee. The superior court entered summary judgment in favor of the Bank. The Hatches appealed, challenging the foundation presented by the Bank to support the admissibility of its mortgage records pursuant to the business records exception to the hearsay rule. The Supreme Court affirmed the summary judgment, holding that court did not abuse its discretion in considering the evidence, as the affidavit was sufficient to support the foundational facts required for the admissibility of the Bank's business records. View "The Bank of Maine v. Hatch" on Justia Law

Following a bench trial in the district court, Defendant John Maynard was convicted of operating while his license was suspended, with a prior conviction (OAS). Maynard appealed, arguing that the Secretary of State's certification of the notice of Maynard's suspension failed to prove the notice element of the OAS charge. The Supreme Court vacated the judgment of the district court, holding that the Secretary of State's certification on its face was inadequate to prove that the court provided Maynard notice of his license suspension, as a Secretary of State's certification that does not set forth any underlying facts pertaining to the notice of suspension does not suffice as proof of notice. View "State v. Maynard" on Justia Law