Justia Maine Supreme Court Opinion Summaries

Plaintiff, a construction company, filed a five-count complaint in superior court against Defendants, alleging breach of contract, quantum meruit, unjust enrichment, and violation of the Prompt Payment Act. In the fifth count of the complaint, Plaintiff sought enforcement of a mechanic’s lien it recorded against Defendants’ property. Plaintiff then moved for summary judgment on its claims for breach of contract, violation of the Prompt Payment Act, and enforcement of the mechanic’s lien. The superior court granted summary judgment for Plaintiff on those three counts but made no mention of Plaintiff’s quantum meruit or unjust enrichment claims. Defendants appealed. The Supreme Court dismissed the appeal as interlocutory, as there was no final judgment on any of Plaintiff’s causes of action where two of Plaintiff’s claims were still pending. View "Warren Constr. Group, LLC v. Reis" on Justia Law

Defendant was at the place of his employment when his employer asked him to submit to a breath test. The results from the employer’s self-contained portable breath-alcohol testing device showed that Defendant had indicators of alcohol in his system, and Defendant was sent home on unpaid leave. Defendant was driving his van after leaving his place of employment when he was stopped and arrested. A police officer administered several field sobriety tests after stopping Defendant. Defendant was subsequently charged with driving under the influence. Before trial, the court granted the State’s motion in limine to exclude any evidence of the workplace breath-alcohol test to challenge the accuracy of the State’s intoxilyzer test. Defendant entered a conditional guilty plea to the charge then appealed the order on the motion in limine. The Supreme Court vacated the judgment, holding that Defendant was entitled to challenge the reliability of the test results offered by the State by any appropriate means that is otherwise admissible in evidence, and thus the trial court denied Defendant the opportunity to make a formal offer of proof by excluding evidence of the workplace breath-alcohol test. View "State v. Adams" on Justia Law

Defendant was charged with three Class E offenses. Defendant posted $500 cash bail in those matters and was assigned an attorney after the court found him indigent. While released on bail, Defendant was indicted on aggravated trafficking of scheduled drugs. Defendant moved for an assignment of counsel in the aggravated trafficking matter. The court granted the motion and ordered that the $500 bail he previously posted be applied to his attorney fees. Following an appeal in which Defendant was represented by his court-assigned attorney, the Supreme Court vacated Defendant’s conviction, and Defendant was acquitted of the aggravated trafficking charge. Defendant’s Class E charges were ultimately dismissed. Defendant then requested the return of his $500 cash bail in the Class E matters. The motions were denied on the grounds that the bail had been applied to counsel fees. The Supreme Court affirmed, holding that even though Defendant was eventually acquitted of the aggravated trafficking charge and his other charges were dismissed did not mean he was relieved of his obligation to pay the ordered portion of his attorney fees. View "State v. Lowden" on Justia Law

Plaintiff sustained injuries when she collided with a bus owned and operated by Defendant. Believing the bus would drive straight, Plaintiff, who was riding a bicycle, began to pass the bus on the right when the bus turned right. Plaintiff hit the side of the bus and then fell under it. A jury found that Defendant was seventy-five percent negligent and that Plaintiff was twenty-five percent negligent. The Supreme Court affirmed, holding (1) 29-A Me. Rev. Stat. 2070 does not protect a motorist from liability merely because a cyclist passes on the right, and therefore, section 2070 did not entitle Defendant to judgment as a matter of law; and (2) the court did not err in declining to instruct the jury on the provisions of 29-A Me. Rev. Stat. 2063(2), which prescribes the circumstances when a cyclist must ride on the right side of a way, as the statute was inapplicable in this case. View "Semian v. Ledgemere Transp., Inc." on Justia Law

In 2010, the Workers’ Compensation Board found that Fay Johnson was injured while working for Home Depot USA, Inc. Home Depot agreed to pay Johnson benefits. In 2012, Johnson went missing. Later that year, Home Depot filed two petitions, one seeking permission to stop paying benefits and the other asking the Board to declare Johnson’s benefits forfeited. A hearing officer ordered that Johnson’s benefits be suspended until Johnson reappeared and dismissed the petition for forfeiture as moot. The Workers’ Compensation Board Appellate Division affirmed. Johnson’s attorney appealed on Johnson's behalf. The Supreme Court affirmed, holding (1) the hearing officer reasonably found that the statutory requirement that petitions for review of incapacity and for forfeiture of benefits be served on “other parties” was satisfied by service on Johnson’s attorney, who continued to represent her before the Board; and (2) the hearing officer had the authority to direct Home Depot to pay Johnsons’ benefits into a segregated account pending a hearing on the petitions and to suspend her benefits following the hearing. View "Johnson v. The Home Depot USA, Inc." on Justia Law

At issue in this case was 110 parcels of property owned by ninety-five separate owners that directly abutted Goose Rocks Beach. In 2009, Beachfront Owners sued the Town of Kennebunkport and all others who claimed any title or right to use the Beach seeking a declaratory judgment affirming his or her ownership and exclusive right to use the portion of the Beach abutting his or her parcel down to the mean low-water mark. The Town counterclaimed alleging its ownership of the Beach and the public’s right to use the Beach. The superior court ultimately awarded the public a recreational easement over both the intertidal and dry sand portions of the Beach. The Supreme Court vacated the judgment, holding that the court erred in awarding the Town a prescriptive easement over the Beach and deciding that the public has a right to engage in ocean-based activities in the intertidal zone pursuant to the public trust doctrine. Remanded. View "Almeder v. Town of Kennebunkport" on Justia Law

After a jury trial, Defendant was convicted of numerous crimes, including two counts of aggravated trafficking of scheduled drugs. The charges stemmed from events that occurred on four different dates - three dates in July and August 2012 and one date in September 2012. On appeal, Defendant argued that the superior court abused its discretion in denying his motion to sever the counts arising from the July and August events from the counts arising from the September events. The Supreme Court affirmed, holding that that superior court did not abuse its discretion in denying Defendant relief from joinder, as, under the circumstances of this case, Defendant failed to make the necessary showing of unfair prejudice required to warrant severance. View "State v. Olmo" on Justia Law

Testa’s, Inc. and Jack and Sherri Coopersmith owned property on the westerly side of Main Street in Bar Harbor. The Coopersmiths owned two contiguous parcels that abutted Testa’s parking lot. In 1978, Testa’s granted the Coopersmiths predecessors-in-title an appurtenant easement over its property. In 2010, Testa’s sued the Coopersmiths seeking a declaratory judgment that the Coopersmiths did not have a right of way over its property. The trial court found that the 1978 agreement was enforceable and created an easement and, alternatively, that the Coopersmiths had a prescriptive easement over Testa’s property. The Supreme Court affirmed without reaching the parties’ prescriptive-easement arguments, holding that the trial court properly concluded that the 1978 agreement was enforceable against Testa’s and granted an appurtenant easement. View "Testa's, Inc. v. Coopersmith" on Justia Law

After a jury trial, Defendant was convicted of aggravated trafficking in scheduled drugs, among other crimes. The Supreme Court affirmed the judgment, holding (1) the evidence was sufficient to support the conviction; (2) the State proved all of the elements of aggravated trafficking where the parties signed a stipulation as to Defendant’s prior conviction for a similar offense but the State failed to formally introduce the stipulation on the record; and (3) the trial court committed plain error by instructing the jury that it did not have to find that the manufacturing process had been completed in order to convict Defendant of the trafficking offense, but the error did not constitute obvious error. View "State v. Fox" on Justia Law

In 2013, the district court entered a judgment granting a divorce to Jeff Emerson and Patricia Bonner. Bonner subsequently filed motions for post-judgment relief pursuant to Me. R. Civ. P. 120 seeking enforcement of the divorce judgment. Emerson filed his own post-judgment motion pursuant to Rule 120 seeking enforcement. The district court employed the “applicable body of law relating to a [Me. R. Civ. P. 60(b) motion]” and, sua sponte, amended the judgment. The Supreme Court vacated the judgment because the court amended the judgment without the authority to do so. Remanded for reconsideration. View "Bonner v. Emerson" on Justia Law