Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court determining that the Aroostook County Commissioners had jurisdiction over an appeal of a municipality's denial of a tax abatement application by Cassidy Holdings, LLC, holding that there was no error.Cassidy, which owned nonresidential property with an equalized municipal valuation of $1 million or greater, requested a partial abatement of its 2021 property taxes. The City of Caribou's Board of Assessors denied the request. The Commissioners declined to hear Cassidy's ensuing appeal on the grounds that they lacked subject matter jurisdiction. The superior court remanded the case for the Commissioners to proceed on the merits, concluding that the Commissioners erred in determining that they lacked jurisdiction over the abatement appeal. The Supreme Judicial Court affirmed, holding that the plain language of 36 Me. Rev. Stat. 844 provides for concurrent jurisdiction before either the Commissioners or the State Board. View "Cassidy Holdings, LLC v. Aroostook County Commissioners" on Justia Law

The Supreme Judicial Court affirmed the order entered in the business and consumer docket granting summary judgment approving the method of the State Tax Assessor for calculating Express Scripts Inc.'s Maine tax liability and denied the Assessor's cross appeal, holding that the trial court did not err.Specifically, the Supreme Judicial Court held (1) the trial court applied an improper standard in evaluating whether Express Scripts established its primary facie case for counts one and two of the petition for review; (2) under the proper legal standard, summary judgment was still appropriate; and (3) the trial court did not err in allowing Express Scripts to file certain information under seal and a later order denying the Assessor's motion to unseal. View "Express Scripts Inc. v. State Tax Assessor" on Justia Law

The Supreme Court reversed the judgment of the decision of the court of appeals reversing the judgment of the superior court dismissing Appellant's lawsuit seeking a declaratory judgment and damages, holding that the superior court erred in dismissing the suit.Appellant brought suit against the Town of Richmond challenging tax assessments imposed on her. The superior court dismissed her complaint on the ground that there was no underlying cause of action to support Appellant's request for a declaratory judgment and that she could not collect damages because she failed to exhaust her administrative remedies. The Supreme Court vacated the judgment below, holding (1) a taxpayer who has been taxed on property that the taxpayer claims is not taxable because the person does not own that property within the meaning of a municipality's statutory authority to tax may challenge the tax on that property either through the statutory abatement process or a declaratory judgment action; and (2) both counts of Appellant's complaint stated a claim. View "Oakes v. Town of Richmond" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court that reversed and modified the decision of the tax assessor of the Town of Vinalhaven denying Hurricane Island Foundation a local property tax exemption under Me. Rev. Stat. 36, 652(1)(B), holding that the Town's tax assessor correctly denied the tax exemption.In denying the Foundation's application, the Town's tax assessor concluded that the Foundation failed to meet the standard for a "literary and scientific" institution under the statute. The superior court twice remanded the case. For both the second and the third time, the assessor denied the tax exemption to the Foundation. The superior court modified the decision to designate the Foundation as tax exempt, concluding that there was an error of law in the assessor's decision. The Supreme Judicial Court vacated the judgment below and remanded for the court to enter a judgment declaring that the Foundation was not exempt, holding that the Foundation failed to show it was a "scientific" institution. View "Hurricane Island Foundation v. Town of Vinalhaven" on Justia Law

The Supreme Judicial Court vacated in part the summary judgment granted in favor of the Maine Tax Assessor entered in the business and consumer docket ruling that TracFone Wireless, Inc.'s Lifeline service was subject to the State of Maine's prepaid wireless fee and service provider tax, holding that summary judgment was improper as to the prepaid wireless fee.On appeal, TracFone also challenged the trial court's denial of its motion to compel the production of documents related to taxpayers similarly situated to TracFone. The Supreme Judicial Court (1) vacated the summary judgment as to the prepaid wireless fee, holding that the lower court erred in concluding that the Lifeline service was "paid for in advance"; (2) affirmed the summary judgment as to the service provider tax because TracFone sold its Lifeline service under Me. Rev. Stat. 36, 2552; and (3) affirmed the order denying TracFone's motion to compel the production of documents. View "State Tax Assessor v. Tracfone Wireless, Inc." 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 affirmed the judgment entered in the business and consumer docket affirming the State Tax Assessor's denial of Appellant's request for an income tax refund for the 2013 taxable year, holding that the superior court did not err.Somerset Telephone Company and affiliated corporations (collectively, Appellant) filed a 2013 Maine tax return showing positive Maine taxable income and state income tax liability. Appellant later filed an amended 2013 return listing an adjusted federal taxable income resulting in a decreased Maine taxable income and decreased tax liability. To account for the difference, Somerset unsuccessfully requested from the Assessor a partial refund. In this ensuing litigation, the business and consumer docket entered a final judgment in the Assessor's favor. The Supreme Judicial Court affirmed, holding that the superior court correctly affirmed the decision of the State Tax Assessor. View "Somerset Telephone Co. v. State Tax Assessor" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court affirming a 2019 decision of the State Board of Property Tax Review granting the tax abatement requests of Expera Old Town, LLC for the 2014 and 2015 tax years for a wood pulp and paper mill, holding that the superior court erred.Expera Old Town, LLC requested tax abatements for 2014 and 2015, but the City of Old Town denied the requests. In 2017, the Board affirmed the City's denial of the requested abatements. The superior court vacated the Board's decision and remanded the case. On remand, in 2019, the Board granted Expera Old Town's tax abatement requests for the same tax years. The Supreme Court vacated the superior court's judgment, holding that Expera Old Town failed to meet its initial burden of showing that the assessments were manifestly wrong. View "City of Old Town v. Expera Old Town, LLC" on Justia Law

In these cases concerning property tax abatement requests the Supreme Judicial Court affirmed two decisions of the superior court vacating a decision denying requests for abatement and granting a petition for judicial review of an adverse decision concerning another request for a tax abatement, holding that the superior court did not err.This consolidated appeal concerned property tax abatement requests made by the Roque Island Gardner Homestead Corporation (RIGHC). The superior court vacated a decision of the Board of Appeals (BOA) of the Town of Jonesport denying RIGHC's requests for abatement concerning three tax years and remanded the matter for the BOA to make an independent determination of the property's fair market value. The court also granted judicial review as to the State Board of Property Tax Review's adverse decision concerning RIGHC's request for another tax year abatement and directed the Town to grant the abatement request. The Supreme Judicial Court affirmed both decisions, holding that the superior court did not err. View "Roque Island Gardner Homestead Corp. v. Town of Jonesport" on Justia Law

The Supreme Judicial Court vacated the superior court's grant of summary judgment concluding that the taxable "sale price" of iPhones sold at discounted prices to customers who entered into wireless service contracts at Apple Inc.'s retail stores did not include payments made by the wireless service carriers to Apple in connection with the sales, holding that the amounts paid by the carriers to Apple constitute part of the taxable sale prices for the phones.In granting summary judgment for Apple and denied the summary judgment motion filed by the State Tax Assessor the superior court concluded that the carriers' payments to Apple were insufficiently linked to the phones' purchases to constitute reimbursement for the discounts. The Supreme Judicial Court vacated the grant of summary judgment and remanded for entry of judgment in favor of the Assessor, holding that because Apple expected at the time of sale it would be reimbursed by the carriers for the price discounts granted to customers entering into wireless service contracts with the carriers, the amounts Apple paid to carriers constituted part of the taxable sale prices for the phones. View "Apple Inc. v. State Tax Assessor" on Justia Law