Justia Maine Supreme Court Opinion Summaries

Fore LLC, a Maine entity, purchased a Maine business from a New Hampshire client of William Benoit, a Massachusetts-based accountant. Fore sued Benoit, alleging that Benoit fraudulently misrepresented that the tax returns he prepared for the Maine business were accurate. The superior court granted Benoit's motion to dismiss for lack of personal jurisdiction. The Supreme Court vacated the superior court's judgment, concluding that Fore made the requisite prima facie showing that Benoit's contacts with Maine were related to the claims in this case and that they were sufficient for the exercise of personal jurisdiction. Remanded to determine whether it was reasonable to require Benoit to defend this action in Maine. View "Fore, LLC v. Benoit" on Justia Law

After Valley Firewood and Tree Farm (collectively, Valley) terminated its firewood business, Gary Voisine, on behalf of Valley, filed a three-count shareholder's derivative action against Valley and Robert Berube, a shareholder and president of Valley. After a bench trial, the superior court found Berube breached his duty to act in good faith toward Valley and awarded damages to Valley in the amount of $1,500,000, with half that sum, $750,000 plus interest and costs, to be paid over to Voisine. At issue on appeal was whether Valley itself was damaged and suffered losses as a result of Berube's conduct and whether Voisine had standing to bring the derivative action on Valley's behalf. The Supreme Court vacated the judgment of the superior court, holding that Voisine lacked standing to bring a shareholder's derivative action on behalf of Valley and was not entitled to damages as a matter of law because Voisine participated in the division of assets of Valley, received the benefits of that distribution, and created a corporation to sell firewood formerly sold by Valley that was intended to replace Valley. View "Voisine v. Berube" on Justia Law

While Shawn Sayer was incarcerated, the district court granted a final order for protection from abuse to Liv Morrison. Sayer appealed, asserting, inter alia, that he was deprived of due process by not being given the opportunity to be present at or participate in the hearing. The Supreme Court vacated the judgment of the district court, holding that Sayer's incarceration and the need to protect his rights by facilitating his participation in the hearing, either in person or by a remote video or audio connection, demonstrated good cause to either make an accommodation to allow him to participate in the hearing or grant a short continuance of the hearing to allow his participation on another date. Remanded. View "Morrison v. Sayer" on Justia Law

Edwin Mitchell, a lobster fisherman, was sued by Victor Ames, who alleged that a group of lobster fishermen had conspired to prevent him from fishing for lobster in the area. The Ames complaint alleged that Mitchell had, among other things, converted Ames's personal property. Mitchell held a homeowners policy with Allstate Insurance Company. By the policy's terms, Allstate agreed to provide a defense if the policyholder was sued for such damages. Allstate, however, declined to provide coverage to Mitchell on the Ames litigation, after which Mitchell sued Allstate for breach of contract. The superior court granted summary judgment in favor of Allstate, concluding that Allstate had no contractual duty to defend Mitchell because a policy exclusion for certain intentional acts applied. The Supreme Court vacated the superior court's judgment, holding that Allstate did have a duty to defend because the liability alleged in the Ames complaint had the potential to result in covered liability. View "Mitchell v. Allstate Ins. Co." on Justia Law

This case involved a dispute between the Mattesons and the Batchelders over fee ownership of less than one acre of land on a stream and the location of a deeded right-of-way on property owned by the Mattesons. The superior court (1) concluded that the Mattesons owned the disputed parcel of land; and (2) reformed the deed to locate the easement along a field road that crossed that Mattesons' property, concluding that the deed description of the right-of-way was ambiguous. The Supreme Court affirmed in part and vacated in part, holding (1) the superior court did not err in finding that the Mattesons obtained the property in dispute, which was included in the deed's property description; and (2) the court erred in reforming the deed to reflect a new location of the easement along the field road where there was no mutual mistake of fact that anything other than the shoreline was the boundary, as described in the deed. Remanded. View "Matteson v. Batchelder" on Justia Law

Arrow Financial Services filed a complaint against Sarah Guiliani alleging breach of contract and unjust enrichment. Arrow then filed a motion for summary judgment seeking to establish that Arrow owned a credit card account registered to Guiliani and that Guiliani owed an unpaid balance of $5044 on the account. In support of its motion, Arrow asserted in an affidavit that it was the assignee of Guiliani's credit card account with Washington Mutural. The district court granted Arrow's motion and awarded Arrow $3493, plus interest and court costs. The Supreme Court vacated the district court's judgment, holding that the district court incorrectly granted summary judgment in favor of Arrow because disputes remained as to material facts regarding the balance due on the account and its assignment to Arrow. View "Arrow Fin. Servs., LLC v. Guiliani" on Justia Law

Laurie Katon was involved in continuing litigation with her daughter and former son-in-law concerning their child, her granddaughter. In the instant case, Katon petitioned for visitation pursuant to the Grandparents Visitation Act. The district court dismissed the petition, concluding that because Katon had improperly withheld her granddaughter from the father, she could not establish standing. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying the petition because the urgent reasons that may justify grandparent visitation consistent with constitutional standards do not exist where a grandparent has improperly withheld a grandchild from his or her parents. View "Katon v. Brandi M." on Justia Law

Humboldt Field Research Institute and Eagle Hill foundation applied for a property tax exemption pursuant to Me. Rev. Stat. 36, 652(1)(A) and (B), which the Town assessors denied. The county commissioners upheld the Town's denial, and the superior court affirmed. Humboldt and Eagle Hill appealed, arguing (1) the Town was required to continue Humboldt's and Eagle Hill's tax exemptions from the prior year, which were based on their status as charitable institutions, absent evidence of an organizational change; and (2) the organizations were exempt as literary and scientific institutions. The Supreme Court affirmed, holding (1) Maine law consistently places the burden on the taxpayer to prove entitlement to a tax exemption, even when an exemption has been granted in prior years, if the assessor challenges the exemption; and (2) the commissioners did not err in determining that Humboldt and Eagle Hill did not meet their burden to prove entitlement to an exemption. View "Humboldt Field Research Inst. v. Town of Steuben" on Justia Law

Larry Hilderbrand, a law enforcement officer employed by the police department, was working with the Maine Drug Enforcement Agency (MDEA) when the county sheriff received a video of Hilderbrand behaving crassly. The sheriff then publicly announced that his department would discontinue working with the MDEA because Hilderbrand was assigned to it and stated that his decision was based on the video. Hilderbrand subsequently filed a three-count complaint against the county commissioners and the sheriff alleging slander per se, invasion of privacy, and negligent infliction of emotional distress. The superior court granted summary judgment in favor of the commissioners and sheriff, concluding that the sheriff had discretionary function immunity and the commissioners could not be liable for the sheriff's conduct because he was not their employee. The Supreme Court affirmed, holding that application of the factors set forth in Darling v. Augusta Mental Health Inst. to the undisputed facts indicated the sheriff's allegedly tortious activities were within the Maine Tort Claim Act's discretionary function immunity provision, and the superior court did not err in dismissing the suit against him on that basis. View "Hilderbrand v. Washington County Comm'rs" on Justia Law

Liberty Group (Liberty) retained Reliable Copy Service (Reliable) to provide services in connection with litigation. Later, Reliable filed a complaint in a Pennsylvania court of common pleas in an effort to collect on the sums owed. The Pennsylvania court subsequently entered a default judgment against Liberty. Following the end of the litigation in the Pennsylvania court, a Maine superior court entered a judgment in favor of Reliable and issued a writ of execution at Reliable's request. Liberty filed a motion for relief from judgment, arguing that the Pennsylvania default judgment was not enforceable in Maine because the Pennsylvania default judgment was void. The superior court denied the motion. The Supreme Court affirmed, holding (1) the Pennsylvania judgment suffered from no jurisdiction defect or due process impediment that would render it void pursuant to Me. R. Civ. P. 60(b)(4); and (2) Liberty's procedural due process rights were not violated when Reliable requested and received from the Pennsylvania court an increased damages award. View "Reliable Copy Serv., Inc. v. Liberty" on Justia Law