Justia Maine Supreme Court Opinion Summaries

While away for a competition in a school-supported event, students caused damage to a motel where they were lodging. The motel's property insurer paid to repair the damage then exercised its right of subrogation pursuant to its insurance contract with the motel to seek to recover compensation for those responsible for the loss. The insurer filed a complaint against the school district, alleging it was liable for breach of contract based on its failure to protect and safeguard the property from damage during the period of occupancy and to refrain from activities that would damage the property. The superior court granted the school district's motion for summary judgment. The Supreme Court affirmed, holding that because the school district did not undertake to be responsible to pay damages in a subrogation action, the insurer's action against the school board was barred. View "Middlesex Mutual Assurance Co. v. Me. Sch. Admin. Dist." on Justia Law

Plaintiffs owned intertidal land on Maine's coast that lay in front of the property of Defendants. Defendants owned a commercial scuba diving business and would walk with their clients from their property onto and across Plaintiffs' intertidal land in order to scuba dive. Plaintiffs filed a declaratory judgment action seeking a determination that Defendants had no right to cross their intertidal land for scuba diving and seeking an injunction prohibiting such use. The superior court granted summary judgment in favor of Defendants, declaring that crossing the Plaintiffs' intertidal land to access the water for recreational or commercial scuba diving was within the public's right to use intertidal land for navigation. The Supreme Court affirmed, holding, as a matter of Maine common law, the public has a right to walk across intertidal lands to reach the ocean for purposes of scuba diving. View "McGarvey v. Whittredge" on Justia Law

Timothy Burns was convicted of theft of unauthorized taking, a Class C offense, following a jury trial. The Supreme Court affirmed the conviction and sentence, holding (1) because the jury could not have rationally found from the evidence that Burns was guilty of theft of property with a value of less than $1000 and because a theft by unauthorized taking is a Class C offense when the property stolen is valued between $1000 and $10,000, the court's failure to instruct the jury concerning the amount necessary to elevate a theft to a Class C offense was harmless; (2) the evidence was sufficient to establish Burns' guilt beyond a reasonable doubt because the jury rationally could have found from the evidence presented at trial that Burns was guilty of the theft of the check involved in this case, and the jury could only have found that the amount stolen was the amount of the check; and (3) the superior court did not err by sentencing Burns to twenty-two months' incarceration. View "State v. Burns" on Justia Law

Sarah Graham filed a complaint against Shyam Brown, alleging physical, emotional, and mental abuse, and seeking damages. Brown did not file an answer, and the district court entered a default against him. After a hearing on damages, the court awarded Graham compensatory damages of $50,000 and punitive damages of $5,000. On appeal, the Supreme Court affirmed, holding (1) the district court did not abuse its discretion by declining to set aside the entry of default; (2) the district court did not err by holding that Brown was liable for intentional infliction of emotional distress and entering a default judgment accordingly; and (3) the district court did not err in its determination of compensatory damages, and the punitive damages award was not excessive. View "Graham v. Brown" on Justia Law

Paul Davis was struck and seriously injured by a truck driven by Edwin Rodriguez. Rodriguez was driving while intoxicated soon after he and Davis exited a chartered bus at the conclusion of a business promotion trip. Rodriguez later pleaded guilty to reckless endangerment, aggravated assault, and DUI. Davis filed claims against the business that organized the trip, its employee, the chartered bus company, and its employee (Defendants) for common law negligence. The superior court granted summary judgment in favor of Defendants. At issue on appeal was whether Defendants owed Davis a common law duty of care. The Supreme Court affirmed the judgment of the superior court, holding (1) the chartered bus company and the employee who drove the bus did not owe Davis a duty to ensure his safety by preventing Rodriguez from driving his truck after the bus trip ended, and (2) the business that organized the trip and its employee did not have a fiduciary duty to Davis because the employee organized and led the excursion. View "Davis v. Dionne" on Justia Law

After being diagnosed with prostate cancer, Philip Baker filed a notice of claim in accordance with the Health Security Act, alleging that his primary care physician violated the applicable standard of care by failing to refer him to a urologist earlier, thus delaying his diagnosis. The superior court granted partial summary judgment to the doctor, finding that the three-year statute of limitations barred Baker's claims for negligent acts or omissions occurring more than three years before he filed his notice. In so ruling, the court declined to recognize the continuing negligent treatment doctrine, which allows a patient to assert a cause of action for professional negligence based upon two or more related negligent acts or omissions by a health care provider or practitioner if some, but not all, of the acts or omissions occurred outside of the statute of limitations period. The Supreme Court vacated the partial summary judgment, holding that the language of the Health Security Act authorizes claims of continuing negligent treatment. Remanded. View "Baker v. Farrand" on Justia Law

Appellants Samantha Young and Rebekah Alley were injured while riding in a vehicle driven by Joshua Weeks. Appellants appealed from a judgment entered in the superior court in which the court held Weeks liable but permitted North East Insurance Company to rescind its automobile insurance policy on the vehicle Weeks was driving. Specifically, Young and Alley challenged the court's entry of summary judgment in favor of North East on its complaint seeking a declaratory judgment that it had no duty to defend or indemnify the driver because Weeks' mother had made material, fraudulent misrepresentations in applying for the automobile insurance. The Court of Appeals vacated the judgment, holding that genuine issues of material fact existed regarding whether Weeks' mother made a material, fraudulent misrepresentation to North East in obtaining the insurance policy. Remanded. View "North East Ins. Co. v. Young" on Justia Law

Marilyn Davis, a hospital employee, was injured when she slipped and fell in the hospital parking lot. The hospital had contracted with Defendants R C & Sons to plow and sand all of its parking areas. At the time Davis was injured, Defendants had not sanded the parking lot. Davis brought suit against Defendants, alleging negligence. Defendants filed a motion for summary judgment, claiming it did not owe Davis a duty of care because Davis was not a third party beneficiary or intended beneficiary of the snow removal agreement. The superior court granted summary judgment in favor of Defendants. On review, the Supreme Court affirmed but on other grounds, holding (1) because Davis was not seeking to enforce the snow removal agreement between the hospital and Defendants, Davis's status as a third-party beneficiary of the agreement was immaterial; and (2) because Davis failed to generate a genuine issue of fact demonstrating the Defendants negligently created a dangerous condition, and because Davis alleged no other grounds to support the imposition of a duty of care, summary judgment was properly granted in favor of Defendants. View "Marilyn R. Davis v. R C & Sons Paving, Inc." on Justia Law

Deutsche Bank National Trust Company, as trustee in trust for the registered holders of Ameriquest Mortgage Securities, Inc., appealed from a summary judgment entered in the district court in favor of Donald and Kim Pelletier on the bank's complaint for foreclosure. The district court concluded that Deutsche Bank had failed to dispute facts asserted by the Pelletiers demonstrating that they had asserted a right of rescission. On appeal, the Supreme Court affirmed the grant of summary judgment, but because the district court's order reached only the point of determining that the Pelletiers were entitled to rescission, the Court remanded for further proceedings to effectuate the rescission. View "Deutsche Bank Nat'l Trust Co. v. Pelletier" on Justia Law

Eli Blackhouse filed a complaint for protection from abuse against Jane Doe, alleging he was a victim of Doe's stalking and asserting that Doe's actions contributed to the deterioration of his health. Blackhouse sought an order prohibiting Doe from having any contact with him or minor children in his charge and from being at or in the vicinity of his residence, school, business, or place of employment without cause. With his complaint, Blackhouse submitted a request for reasonable accommodation, stating he was disabled and unable to be physically present in court. The district court denied Blackhouse's request for an ex parte temporary order of protection from abuse and dismissed his complaint after Blackhouse failed to appear for the final hearing. There was no indication that Blackhouse's request for reasonable accommodation was called to the court's attention or that the court otherwise reviewed it before dismissing the complaint. On appeal, the Supreme Court vacated the dismissal, holding that the district court erred by dismissing Blackhouse's complaint without first considering his request for reasonable accommodation of his claimed disability. Remanded. View "Blackhouse v. Jane Doe" on Justia Law