Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated in part and affirmed in part the lower court's judgment in favor of Plaintiffs and against Compass Harbor Village Condominium Association and Compass Harbor Village, LLC (collectively, Compass Harbor), holding that the court erred in ordering specific performance and entering judgment for Plaintiffs on the claim brought pursuant to the Maine Unfair Trade Practices Act (UTPA), Me. Rev. Stat. 5, 205-A to 2014.Plaintiffs brought suit alleging that Compass Harbor's actions with respect to maintenance and governance of the Association caused their units to lose value. The lower court found that Compass Harbor breached the contracts between it and Plaintiffs, the LLC violated its fiduciary duties to Plaintiffs, and Compass Harbor violated section 207 of the UTPA. The court awarded damages to Plaintiffs and entered an order of specific performance requiring Compass Harbor to abide by its contractual and fiduciary duties in the future. The Supreme Judicial Court vacated the judgment in part, holding (1) the UTPA did not apply in this case; (2) the court did not clearly err in calculating damages; and (3) the court went beyond its discretion in entering an order that would involve the court in continuous supervision of Compass Harbor's performance over an indefinite period. View "Brown v. Compass Harbor Village Condominium Ass'n" on Justia Law

The Supreme Judicial Court vacated the superior court's judgment dismissing with prejudice the foreclosure complaint filed by a Bank and affirmed the order of sanctions imposed on the Bank, holding that the complaint should have been dismissed without prejudice.On remand from the Supreme Judicial Court, the superior court granted the Bank's motion to voluntarily dismiss its foreclosure complaint without prejudice. Thomas Manning filed a motion for reconsideration of the court's order. After judicial settlement conferences, Manning filed a renewed motion for contempt against the Bank for its conduct at the settlement conference. Manning argued that the court should dismiss the foreclosure complaint with prejudice or, in the alternative, hold the Bank in contempt and impose sanctions. The court granted the motion for contempt and imposed sanctions, ordering the Bank to pay Manning's attorney fees and costs. The court then granted Manning's earlier motion for reconsideration and dismissed with prejudice the Bank's foreclosure complaint as a sanction for the Bank's conduct at the judicial settlement conference. The Supreme Judicial Court vacated the judgment in part, holding that the trial court abused its discretion in both granting Manning's motion for reconsideration and imposing sanctions on the Bank, including a dismissal with prejudice of the foreclosure complaint. View "U.S. Bank National Ass'n v. Manning" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court partitioning real property in Kittery held by Toralf Strand and Sabrina Velandry as tenants in common, holding that the court did not err in dividing equally the value of the property after crediting Strand with the amount his spent for insurance, repairs, improvements, and real estate taxes.In 2014, Strand signed a purchase and sale agreement solely in his name to buy the house and included Velandry on the deed as a tenant in common. After the parties separated, Strand filed a complaint for equitable partition of the property pursuant to 14 Me. Rev. Stat. 6051(7). The court awarded Strand the amount his spent on insurance, improvements, repairs, and real estate taxes and then divided the property's remaining appraisal value equally between Strand and Velandry. The Supreme Judicial Court affirmed, holding (1) because the court found that Strand did not condition Velandry's interest as a tenant in common on her agreement to pay Strand half of the property's purchase price, the court did not err in applying the presumption of equal ownership and entering judgment accordingly; and (2) the court did not clearly err in disallowing certain of Strand's claimed credits and set-off. View "Strand v. Velandry" on Justia Law

The Supreme Judicial Court affirmed the judgment of foreclosure entered by the district court in favor of U.S. Bank, holding that the district court did not err in concluding that U.S. Bank had standing to foreclose.U.S. Bank filed a complaint for foreclosure. At a hearing, the court admitted, over Jim Gordon's objection, a copy if a 2016 "Ratification of Assignment" stating that Mortgage Electronic Registration Systems, Inc., as nominee for EquiFirst Corporation, assigned the mortgage in this case to U.S. Bank. The court ultimately concluded that U.S. Bank had standing to foreclose pursuant to the 2016 ratification and entered a judgment of foreclosure in favor of U.S. Bank. The Supreme Judicial Court affirmed, holding (1) the court did not abuse its discretion by admitting the copy of the 2016 ratification; and (2) the court did not err in concluding that U.S. Bank had standing. View "U.S. Bank National Association v. Gordon" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court ordering the turnover and sale of Travis Otis's boat satisfy a money judgment against him in favor of Erik Wuori, holding that the court erred in concluding that the boat was not used "primarily for commercial fishing" within the meaning of Me. Rev. Stat. 14, 4422(9) and was therefore not exempt from attachment and execution.The boat at issue was a thirty-six-foot boat that Otis used to catch lobsters for the Maine Department of Marine Resources in order to collect data on juvenile lobsters. The district court concluded that the boat was not exempt from attachment and execution because Otis did not harvest the lobster he caught but, rather, returned them to the ocean. Thus, the court reasoned, Otis did not use the boat "primarily for commercial fishing." The Supreme Judicial Court vacated the judgment, holding that because Defendant's hauling and catching was compensated by the Department, the use of his boat constituted "commercial fishing." View "Wuori v. Otis" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court in favor of Defendants following a bench trial on Plaintiffs' claims against Defendants stemming from Plaintiffs' purchase of Defendants' house, holding that the trial court's factual findings were supported by the evidence and that the court did not err in deciding in favor Defendants.Defendants entered into a purchase and sale agreement with Plaintiffs to sell Defendants' home. After Plaintiffs discovered a number of deficiencies in the house they filed a complaint alleging counts arising from the house's sale and defects. The trial court granted judgment in favor of Defendants. The Supreme Judicial Court affirmed, holding that the trial court's explicit findings were comprehensive, detailed, and adequately supported by record evidence. View "Wuestenberg v. Rancourt" on Justia Law

In this declaratory judgment action contesting the ownership of certain property the Supreme Judicial Court vacated the final judgment entered on behalf of Lisa Yorke finding that Brad Belanger's deed to Rebecca Belanger was not supported by consideration, holding that the trial court did not apply the correct legal standard to resolve the issue of consideration.Brad deeded the property at issue to Lisa, his daughter, before he deeded it to Rebecca, his wife. Rebecca recorded her deed before Lisa recorded hers. Both Lisa and Rebecca claimed exclusive title to the property and sued each other for a declaratory judgment that each woman owned the property. The court found that Brad's deed to Rebecca was not supported by consideration and, therefore, she was not a bona fide purchaser of the property. The court entered final judgment for Lisa. The Supreme Judicial Court vacated the judgment in part, holding (1) the trial court correctly found that Me. Rev. Stat. 33, 480, which requires the signature of a nonowner spouse on a transfer of real property in certain circumstances, was not an affirmative defense to Lisa's ownership claim; and (2) the trial court did not apply the correct legal standard to resolve the issue of consideration. View "Belanger v. Yorke" on Justia Law

The Supreme Judicial Court vacated the order of the district court granting the Town of Gorham's motion to enforce a consent decree entered earlier in a land-use dispute, holding that there was not a proper record to support the trial court's findings.The Town filed a land-use enforcement claim in the district court charging Defendants with violations of the Gorham Land Use and Development Code. The parties settled the dispute by agreeing to terms set forth in a consent decree, and the trial court ordered the consent decree to be entered as a judgment. The Town then filed a motion to enforce the consent decree, alleging noncompliance on the part of Defendants. The court granted the Town's motion. The Supreme Judicial Court vacated the judgment below, holding that the court order was not supported by competent evidence in the record. View "Town of Gorham v. Duchaine" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court affirming the second decision of the Scarborough Board of Assessment Review granting Taxpayers 14.74 percent abatements to their land values, holding that the Board's original abatements reviewed by the superior court after this Court's remand satisfied constitutional requirements.In previous opinions, the Supreme Judicial Court concluded that the Board had erred in denying Taxpayers' abatement requests to their land values. On remand, the Board granted Taxpayers eight percent abatements to their land values. The superior court vacated the Board's decision, concluding that the Board's abatement formulate was unreasonable. On remand, the Board determined that Taxpayers were entitled to 14.74 percent abatements. The superior court affirmed. The Supreme Judicial Court vacated the superior court's judgment affirming the Board's second decision granting 14.74 percent abatements and remanded with directions to affirm the Board's first decision, holding that the Board's original decision was not outside the reasonable range of discretion allowed the Board under this Court's precedents. View "Bolton v. Town of Scarborough" on Justia Law

The Supreme Judicial Court vacated the judgment of the Business and Consumer Docket (BCD) in favor of the Town of Bar Harbor on Landowners' complaint seeking a declaratory judgment that the Town's Zoning Ordinance Amendment was invalid, holding that Landowners failed to demonstrate a particularized injury and commenced this action prematurely.The Department of Environmental Protection (DEP) issued an order approving the Amendment, which changed the Town's Land Use Ordinance by, among other things, creating a new Shoreland Maritime Activities District that would apply to the Town's Ferry Terminal Property. Landowners, individuals whose properties had views overlooking the waters adjacent to the Town's Ferry Terminal Property, sought a declaratory judgment that the Amendment was invalid. The BCD entered judgment for the Town. Landowners appealed, arguing that the Amendment was inconsistent with state law and that the court erred in deferring to the order of the DEP in approving the Amendment. The Supreme Judicial Court vacated the court's judgment on standing and ripeness grounds and remanded the case for dismissal without prejudice, holding that Landowners lacked standing to challenge the Amendment and that their claim was not ripe. View "Blanchard v. Town of Bar Harbor" on Justia Law