Justia Maine Supreme Court Opinion Summaries

Plaintiff’s employment as a corrections officer at the county jail was terminated as a result of an incident with an inmate. Although Plaintiff was reinstated to his position at the jail, the Board of Trustees of the Maine Criminal Justice Academy suspended Plaintiff’s corrections-officer certificate for one year, finding that Plaintiff recklessly caused bodily injury or offensive physical contact to an inmate and that this conduct constituted a gross deviation from the standard of conduct. The Supreme Court affirmed, holding that the Board did not abuse its discretion in issuing a one-year suspension in this case. View "Stein v. Me. Criminal Justice Academy" on Justia Law

When Douglas Going did not inherit land owned by his parents, Going sent a notice of demand to his cousin, Alayna Laprel, and her husband, Neal Smith, who had lawfully purchased the land from Going’s father. In the notice, Going called Laprel a “thief.” Going then purported to place and record a “commercial lien” on the property. Laprel and Smith filed a complaint seeking a declaration that the purported lien was baseless and alleging claims for, inter alia, slander, libel, and slander of title. The superior court entered summary judgment in favor of Laprel and Smith on their declaratory judgment claim and on their claim for slander of title. The Supreme Court affirmed, holding (1) the superior court did not lack jurisdiction to act in this case; and (2) the superior court did not err in failing to dismiss without prejudice Laprel’s and Smith’s own slander of title claim. View "Laprel v. Going" on Justia Law

In 2012, Sarah Clifford and Debra Clifford petitioned the probate court for temporary guardianship of Tasha Young’s minor child. The court granted the Cliffords a temporary guardianship for a period of six months. Young appealed, arguing that the evidence was insufficient to support the award of temporary guardianship and that the court erred in its evidentiary rulings at trial and in denying her request for expert witness fees. Because the temporary guardianship expired by the time the Supreme Court heard the appeal, the matter was moot, and the Court dismissed the appeal. View "In re Guardianship of Young" on Justia Law

Janet Howe and Rajesh Mandekar (together, Howe) owed a condominium in the River Knoll Farms Condominium. The condominium association (Association) sued Howe for negligence, nuisance, and keeping a dangerous dog. MMG Insurance Company, which had issued a homeowner’s policy to Howe, declined to defend Howe in the litigation. The trial court subsequently declared that MMG had no duty to defend in the suit, concluding that the policy issued to Howe did not provide coverage because the Association’s suit sought only equitable relief. The Supreme Court vacated the judgment of the superior court, holding that MMG had a duty to defend Howe in the suit because the complaint alleged facts that would support claims potentially falling within the coverage of the policy. View "Howe v. MMG Ins. Co." on Justia Law

After a hearing, the superior court determined that Dan Brown, a farmer in Blue Hill, unlawfully sold milk without a milk distributor’s license, sold unpasteurized milk in containers that were not labeled “not pasteurized,” and operated a food establishment without a license. The Supreme Court affirmed, holding (1) the superior court did not err in concluding that equitable estoppel did not bar the State from enforcing its licensing requirements for raw milk distributors; (2) the Blue Hill ordinance exempting local food producers and processors from municipal licensing and inspection requirements did not exempt Brown from the State’s licensing requirements; and (3) Brown did not substantially comply with raw milk labeling requirements by posting a small sign at his farm stand. View "State v. Brown" on Justia Law

Plaintiff was treated by a surgeon at Central Maine Medical Center (CMMC) for abdominal pain. The doctor informed Plaintiff that he may be suffering from either hepatic or pancreatic cancer, which has a very low survival rate. Several weeks later, test results revealed that Plaintiff actually suffered from B-cell non-Hodgkins lymphoma, which has a five-year survival rate of up to ninety percent. Plaintiff complained, and CMMC’s president sent a letter to Plaintiff that CMMC claimed was “an expression of sympathy or benevolence” and an “offer to compromise.” Plaintiff subsequently filed a medical malpractice action against CMMC. CMMC moved to exclude from evidence the letter from CMMC’s president to Plaintiff, but the trial court admitted into evidence a redacted version of the letter. The jury returned a $200,000 verdict in Plaintiff’s favor. The Supreme Court affirmed, holding that the superior court (1) did not err by admitting the portion of the letter that contained an admission of fault, as statements of fault are admissible under the Apology Statute; and (2) properly concluded that the statements contained in the letter were not made as part of a settlement negotiation or mediation. View "Strout v. Cent. Me. Med. Ctr." on Justia Law

The State seized twenty-six cats in Defendant’s home and spent $36,800 to treat, house, and care for the cats. Defendant was ultimately convicted of cruelty to animals. Defendant was prohibited from owning any animals except two spayed or neutered cats and required to pay $18,000 in restitution to the State. The Supreme Court affirmed the district court’s judgment, holding (1) the district court did not abuse its discretion in quashing a subpoena that would have compelled one of Defendant’s witnesses to testify; (2) Maine’s cruelty-to-animals statute is not unconstitutionally vague; and (3) there was sufficient evidence to sustain a finding of cruelty to animals and to support the district court’s restitution order. View "State v. Peck" on Justia Law

Ruth married Donald on the same day that she executed a will. Ruth died the following day. Donald was appointed personal representative, and the will was informally admitted to probate. Jennifer, Ruth’s daughter, filed a petition for a formal adjudication of intestacy and for her appointment as personal representative, alleging that Ruth lacked the capacity to execute the will. The probate court denied Jennifer’s petition and admitted the will to probate, concluding that Donald sustained his burden of showing due execution of the will and that Jennifer failed to prove the absence of testamentary capacity by a preponderance of the evidence. The Supreme Court affirmed, holding that the probate court did not err in its evidentiary rulings and did not err in finding that Ruth had the requisite testamentary capacity to execute a will. View "Estate of O'Brien-Hamel" on Justia Law

Defendant entered into a land installment contract that established the terms of a transfer from Plaintiffs to Defendant of a parcel of land. Defendant failed to make the payments required by the contract, and Plaintiffs commenced this action. Defendant argued that because the contract did not comply with 33 Me. Rev. Stat. 482(1) Plaintiffs were barred from obtaining relief. The district court entered a judgment of foreclosure against Defendant and ordered a writ of possession in favor of Plaintiffs, concluding that, even if the contract failed to comply with section 482(1), Plaintiffs would have had could obtain possession of the property through the forcible entry and detainer process. The Supreme Court affirmed, holding (1) the contract was enforceable because it was in substantial compliance with section 482(1); and (2) 14 Me. Rev. Stat. 6203-F does not require a court to order a public sale of property when ordering a foreclosure on a land installment contract. View "Thurston v. Galvin" on Justia Law

Michael Weatherbee brought litigation to recover money misappropriated by his sister, Peggy McPike, while she was handling their parents’ money before their deaths. The superior court entered judgment in favor of the parents’ estates in the amount of $92,400 in restitution. The probate court subsequently directed that Weatherbee be compensated of the estates for attorney fees and expenses. McPike appealed, claiming, among other things, that the probate court erred in applying the common fund doctrine to require that attorney fees be paid by the estates. The Supreme Court vacated the judgment, holding that neither the common fund doctrine nor the Probate Code nor any other equitable exception to the American Rule provided a basis for the award of attorney fees out of the estates. View "In re Estate of Weatherbee" on Justia Law