Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the superior court vacating the determination of the Town of Wells Zoning Board of Appeals (ZBA) denying Plaintiff's application for two setback variances on the grounds that Plaintiff had not met his burden of proof, holding that the evidence did not compel the ZBA to grant him a variance.The ZBA denied Plaintiff's application on the basis that he did not meet his burden of proof to show that granting the variances would not alter the essential character of the locality. The superior court vacated the ZBA's determination, concluding that Plaintiff had met his burden of proof. The Supreme Judicial Court vacated the judgment below and remanded with instructions to affirm the ZBA's denial, holding that the ZBA properly decided that Plaintiff failed to show that the nature of his proposed residence with the variances would conform with the neighborhood as zoned and would not degrade the value of surrounding environmental structures. View "Hill v. Town of Wells" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming a decision of the State Board of Property Tax Review upholding the Town of Madison's denial of Madison Paper Industries' (MPI) request for a property tax abatement for the 2016-17 tax year, holding that the Board made no errors of law, and its findings were supported by competent evidence in the record.The Board found MPI's appraisal and its underlying factual assertions were not credible and that MPI had failed to meet its burden of persuasion. On appeal, MPI argued that the Board failed to apply the Maine Constitution's required that it apply the "just value" standard to valuing the property. The Supreme Judicial Court affirmed, holding that the Board's determinations were not erroneous and that its findings were supported by the evidence. View "Madison Paper Industries v. Town of Madison" on Justia Law

The Supreme Judicial Court vacated the decision of the superior court affirming the judgment of the district court entered in the Business and Consumer Docket in favor of Ocean State Job Lot of Maine 2017 LLC and dismissing the action brought by 20 Thames Street LLC and 122 PTIP LLC (collectively, 20 Thames) for forcible entry and detainer (FED), holding that the district court erred.In granting Ocean State's motion to dismiss, the district court determined that 20 Thames's complaint for FED was barred by the claim preclusion branch of res judicata. The superior court affirmed. On appeal, 20 Thames argued that the trial court erred in dismissing the action on claim preclusion grounds because one claim was not and could not have been litigated in an earlier action. The Supreme Court agreed and reversed, holding (1) claim preclusion did not apply; and (2) where it was impossible to discern definitively what was litigated and decided in the earlier action, issue preclusion should not foreclose an inquiry into the merits. View "20 Thames Street LLC v. Ocean State Job Lot of Maine 2017 LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Business and Consumer Docket in favor of JJ Cars, LLC and John Mokarzel on H&B Realty, LLC's complaint for breach of contract, holding that there was no error in the court's judgment.The lower court determined that H&B breached the lease in this case by unreasonably withholding consent to a proposed sublease. On appeal, H&B argued that the court erred in applying the affirmative defenses, as pleaded by JJ Cars and Mokarzel, of breach of contract and failure to mitigate damages. The Supreme Judicial Court affirmed, holding that there was competent record evidence to support the court's finding that H&B materially breached the lease by refusing to consent to sublet the property. View "H&B Realty, LLC v. JJ Cars, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Appellant's complaint for lack of subject matter jurisdiction, holding that the superior court did not err in determining that Appellant's dispute with Regina Petit and the Passamaquoddy Tribe was an "internal tribal matter."After Appellant contacted the Chief of Police for the Passamaquoddy Tribe and caused Appellant to be served with a no-trespass notice, Appellant filed a complaint against Petit and the Tribe. The superior court granted Petit and the Tribe's motion to dismiss for lack of subject matter jurisdiction, concluding that the dispute involved an "internal tribal matter." The Supreme Judicial Court affirmed, holding that the most appropriate forum for this case was the tribal court. View "Moyant v. Petit" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court in favor of Deutsche Bank on Deutsche Bank's foreclosure complaint, holding that the district court did not err or abuse its discretion.On appeal, Stephen Clifford argued that the district court abused its discretion by admitting several documents under the business records exception to the rule against hearsay and erred in finding that Deutsche Bank satisfied the elements of proof to support the judgment of foreclosure. The Supreme Judicial Court disagreed, holding (1) the trial court did not abuse its discretion by admitting the documents under the business records exception; and (2) Deutsche Bank proved all the required elements to foreclose by a preponderance of the evidence. View "Deutsche Bank Trust Co. Americas v. Clifford" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court in favor of John Bump on Wells Fargo Bank's foreclosure complaint, holding that the court did not err by concluding that a 2015 order dismissing without prejudice Wells Fargo's earlier action seeking foreclosure on the same mortgage did not vacate the final judgment in Bump's favor that had been entered in 2013 in that same case.Wells Fargo filed a foreclosure action in the district court in 2009. After a bench trial in 2013, the court entered judgment on the merits in favor of Bump. In 2015, the court granted Wells Fargo's motion to dismiss the 2009 action without prejudice. In 2016, Wells Fargo filed a new action to foreclose on the same mortgage. In 2020, the court entered judgment in favor of Bump, stating that it took notice of the 2013 final judgment and concluding that the 2015 order of dismissal without prejudice did not operate to vacate that judgment. The court then determined that Wells Fargo's entire claim was barred by res judicial given the 2013 judgment. The Supreme Judicial Court affirmed, holding that the district court (1) properly concluded that the preclusive effect of the 2013 judgment barred the present action; and (2) did not abuse its discretion in taking judicial notice of the prior judgment. View "Wells Fargo Bank v. Bump" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered by the superior court ejecting Defendant from real property pursuant to Me. Rev. Stat. 14, 6701-7053, holding that the trial court properly entered judgment for Plaintiffs, the property owners.Plaintiffs filed a complaint seeking to eject Defendant from the property and obtain a writ of possession. The trial court granted Plaintiffs' motion for summary judgment for their claim of ejectment. The Supreme Judicial Court affirmed, holding that the trial court (1) correctly interpreted Me. Rev. Stat. 14, 6961 and the legal framework governing real actions for ejectment; (2) did not err in entering partial summary judgment for Plaintiffs granting them a writ of possession; and (3) did not err in concluding that its judgment rendered Defendant's counterclaim for declaratory judgment moot. View "Ogden v. Labonville" on Justia Law

In this appeal from a residential foreclosure judgment, the Supreme Judicial Court clarified the criteria under the business record exception to the hearsay rule for admitting into evidence records that a business has obtained from another entity and integrated into its own records or operations by reaffirming the interpretation set forth in Northeast Bank & Trust Co. v. Soley, 481 A.2d 1123, 1127 (Me. 1984).Specifically, the Supreme Court held that a record that one business has received from another is admissible under Me. R. Evid. 803(6) without testimony about the practices of the business that created the record, provided that (1) the proponent of admission establishes that the receiving business has integrated the record into its own records, has established the accuracy of the contents of the record, and has relief on the record in the conduct of its operations; and (2) the opponent of admission has not shown that the record is nonetheless not sufficiently trustworthy to be admitted. View "Bank of New York Mellon v. Shone" on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the superior court denying U.S. Bank Trust, N.A.'s motion to extend the time to file a notice of appeal as to its foreclosure complaint against James D. Keefe, holding that the trial court did not err in denying the motion as untimely.In denying U.S. Bank's motion seeking an extension of time to file its notice of appeal the trial court determined determined that U.S. Bank had shown good cause for the trial court to grant its motion to extend but that its authority to grant an extension of time had expired, and therefore, the motion was untimely. The Supreme Judicial Court affirmed, holding that the trial court did not err in its interpretation of the pertinent Rules of Appellate Procedure or in denying U.S. Bank's untimely motion for an extension of time. View "U.S. Bank Trust, N.A. v. Keefe" on Justia Law