Justia Maine Supreme Court Opinion Summaries

After resigning from her job as director of nursing at St. Joseph’s Rehabilitation and Residence, Plaintiff sued St. Joseph’s under the Whistleblowers’ Protection Act, alleging retaliation and constructive discharge. The trial court granted summary judgment for St. Joseph’s on Plaintiff’s constructive discharge claim and, after a trial, the jury rendered a verdict for St. Joseph’s on the retaliation claim. Plaintiff appealed, challenging the entry of summary judgment on her constructive discharge claim. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in addressing the constructive discharge claim separately on the motion for summary judgment; and (2) the court properly entered summary judgment for St. Joseph’s on the constructive discharge claim. View "Sullivan v. St. Joseph's Rehab. & Residence" on Justia Law

In 2011, Dennis Kay was driving a van owned by Budget Truck Rental when the van slid off an icy road. Kay was ejected from the vehicle and died as a result of the accident. Kay was driving the vehicle during the course of his employment with Douglas Wiggins, who died in 2013 of unrelated causes. Kay’s estate brought a wrongful death action against Wiggins’s estate and Budget Truck. The lower court granted summary judgment in favor of Wiggins and Budget Truck, concluding (1) Kay’s claim was barred by the exclusivity provisions of the Workers’ Compensation Act (Act), and (2) Budget Truck did not proximately cause Kay’s injuries. The Supreme Judicial Court affirmed, holding (1) the court did not err in granting summary judgment for Wiggins on the ground that Kay’s claim was barred by the Act; and (2) the court did not err in granting summary judgment for Budget Truck. View "Estate of Kay v. Estate of Wiggins" on Justia Law

The probate court issued an adjudication of incapacity and appointed the Department of Health and Human Services as the public guardian of Harold Sanders, finding that Sanders was incapacitated, that no suitable private guardian was available, and that the appointment of a public guardian was necessary or desirable. Sanders appealed, arguing that the probate court did not have jurisdiction to appoint a guardian for him because his situation did not comport with any basis for jurisdiction in the adult guardianship statute. The Supreme Judicial Court agreed and vacated the judgment of the probate court, holding that Me. Rev. Stat. tit. 18-A, 5-523(b)(3) did not vest the court with jurisdiction to appoint a nontemporary guardian for Sanders. View "In re Guardianship of Harold Sanders" on Justia Law

In 2011, Father and Mother were divorced pursuant to a divorce judgment. In 2015, the district court found Father in contempt for violating the divorce judgment. The court also denied Father’s motion to modify his child support obligation. The Supreme Court vacated in part and affirmed in part, holding (1) the court did not abuse its discretion by finding Father in contempt for nonpayment of child support for the years 2011, 2013 and 2014; (2) the court erred by finding that Father had not fully paid child support for 2012 and that he was in contempt for nonpayment for that year; (3) the court did not err by finding that there was no substantial change in circumstances warranting a modification of Father’s child support obligation; and (4) the court did not err by determining that Father was obligated to sell the marital home and to divide the proceeds pursuant to the terms of the divorce agreement. View "McCarthy v. Goroshin" on Justia Law

Camden National Bank filed a complaint for foreclosure against Ilene Weintraub. Weintraub brought several counterclaims against the bank, including violations of the Maine Consumer Credit Code, breach of contract, and a claim for intentional infliction of emotional distress, alleging that she suffered injuries as a direct and proximate result of the abuse conduct of the Bank’s collections department and an accusation of criminal conduct. The Bank filed a special motion to dismiss requesting dismissal of several claims based on Maine’s anti-SLAPP statute, but failing to request dismissal of the breach of contract claim. The superior court concluded that the anti-SLAPP statute prohibits selective dismissal of claims and that Weintraub met her burden of demonstrating a prima facie case of actual injury and causation. The Supreme Judicial Court affirmed, holding that the trial court (1) erred in holding that the anti-SLAPP statute did not allow for selective dismissal of some, but not all, of Weintraub’s counterclaims, but the error was harmless; and (2) did not err in concluding that Weintraub met her burden of showing prima facie evidence of causation. View "Camden Nat’l Bank v. Weintraub" on Justia Law

Plaintiff filed a complaint for negligence and wrongful death against Defendant, who owned and operated a guesthouse at which Plaintiff’s wife died. Plaintiff alleged that the guesthouse premises were unreasonably dangerous and that defects in the staircase of a bedroom were a proximate cause of his wife’s fatal injuries. The trial court entered summary judgment in favor of Defendant, concluding that Plaintiff failed to present a prima facie case that Defendant’s alleged negligence was a proximate cause of his wife’s fatal injuries. The Supreme Court affirmed, holding (1) the trial court did not err by disregarding certain statements in Plaintiff’s affidavit and the affidavit of his expert witness; and (2) the evidence could not not support a finding that Defendant’s allegedly unsafe premises bore a causal connection to Plaintiff’s wife’s injuries. View "Estate of Smith v. Salvesen" on Justia Law

In 2012, Nationstar Mortgage LLC filed a foreclosure action against Timothy Halfacre. The trial court entered judgment for Halfacre. Nationstar subsequently filed a new foreclosure action against Halfacre. The superior court concluded that the foreclosure action was barred by the doctrine of res judicata. On appeal, Nationstar asserted that it lacked standing to bring the action, and therefore, the action should be dismissed without prejudice. The Supreme Court vacated the trial court’s judgment and dismissed the case, holding that Nationstar lacked standing to foreclose on the mortgage. Further, the Court left to the trial court the determination of whether a sanction should be imposed in this matter. View "Nationstar Mortgage LLC v. Halfacre" on Justia Law

Lois Young filed a complaint claiming that her transfer of her home to her former foster child, Joseph Lagasse, and his wife was the result of undue influence and therefore should be voided. The trial court concluded Plaintiff did not meet her burden of establishing that the property transfer was improvident transfer of title within the meaning of the Improvident Transfers of Title Act, and therefore denied relief. The Supreme Court affirmed, holding (1) the superior court did not err by not applying a statutory presumption that a transfer of assets by an elderly, dependent person is a result of undue influence unless that person was represented by independent counsel at the time of the transfer; and (2) the record supported a finding that the transfer was not the result of undue influence. View "Young v. Lagasse" on Justia Law

Defendant entered a conditional plea of nolo contendere to the crime of operating after suspension. A judgment of conviction was entered accordingly. Defendant appealed, arguing that the lower court erred in denying his motion to suppress because the law enforcement officer’s decision to stop his vehicle was pretextual and the stop was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding that the record supported the court’s inferred finding that the stop was supported by a reasonable articulable suspicion of a threat to public safety, and therefore, the lower court did not err in denying Defendant’s motion to suppress. View "State v. Sasso" on Justia Law

This case involved a dispute primarily among siblings regarding the substance of and rights to their mother’s estate. Plaintiff commenced an action against Defendants for tortious interference with an expectancy of an inheritance. The superior court granted summary judgment in favor of Defendants, concluding that Plaintiff did not make a prima facie case for the causation element of his cause of action. The Supreme Judicial Court affirmed, holding that Plaintiff could not establish a prima facie case for tortious interference with an expectancy interest, and therefore, the trial court did not err in granting the motion for summary judgment in favor of Defendants. View "Cote v. Cote" on Justia Law