Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the divorce judgment entered by the district court that awarded shared parental rights and responsibilities concerning the parties' minor children, holding that the court impermissibly based its determination on hearsay evidence.At issue before the Supreme Court was the admission of testimonial evidence regarding Father's substantiation by the Department of Health and Human Services for sexual abuse of a child. On appeal, Father argued that the evidence regarding his substantiations was inadmissible hearsay and that the evidence prejudiced him. The Supreme Judicial Court vacated the judgment below, holding (1) the evidence regarding Father's substantiation was inadmissible hearsay; and (2) the error was not harmless. View "Needham v. Needham" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court denying the motion to compel arbitration brought by Uber Technologies, Inc. and Rasier, LLC (collectively, Uber) in this action brought by Patricia Sarchi, a user of Uber's ride-sharing service, and the Maine Human Rights Commission, holding that the superior court did not err.Plaintiffs brought this action against Uber for violating the Maine Human Rights Act, Me. Rev. Stat. 5, 4592(8), 4633(2), after Sarchi, who was blind, was refused a ride because of her guide dog. Uber moved to compel Sarchi to arbitrate and to dismiss or stay the action pending arbitration. The motion court denied the motion to compel, concluding that Sarchi did not become bound by the terms and conditions of Uber's user agreement. The Supreme Judicial Court affirmed, holding that, under the facts and circumstances of this case, Sarchi was not bound by the terms. View "Sarchi v. Uber Technologies, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court in favor of Quang Pham on Atlantic Home Solutions, Inc.'s claim for recovery of personal property pursuant to Me. Rev. Stat. 14, 7071, holding that there was no error.Atlantic sought a judgment and writ of possession authorizing it to take possession of a modular home, the appliances, and the heating unit by removing them from Pham's property. The trial court issued judgment in favor of Pham, concluding that the modular home and other items no longer constituted personal property because they had become part of Pham's real estate. The Supreme Judicial Court affirmed, holding that the trial court did not misapply the law, and its findings were supported by the record evidence. View "Atlantic Home Solutions, Inc. v. Pham" on Justia Law

The Supreme Judicial Court affirmed in part the judgment entered in the Business and Consumer Docket (BCD) awarding attorney fees and expenses to Forney & Weygandt, Inc. (F&W) but vacated a portion of the judgment awarding F&W attorney fees and expenses related to subcontractor claims, holding that remand was required.Lewiston DMEP IX, LLC, et al. (collectively, GBT), a group of limited purpose entities and a commercial real estate developer, appealed the attorney fees and expenses award to F&W, a commercial general contractor, pursuant to Maine's prompt payment statute, Me. Rev. Stat. 10, 1111-1120. Specifically, GBT contended that the BCD erred in awarding attorney fees and expenses that were not incurred in direct pursuit of F&W's prompt payment claims, including those related to F&W's contract claims, GBT's counterclaims and affirmative defenses, and subcontractor claims against F&W. The Supreme Judicial Court largely affirmed the judgment but vacated the award of attorney fees and expenses related to the subcontractor claims, holding that the court abused its discretion when it did not articulate a basis for an award of fees that would be proper under the prompt payment statute and this Court's interpretative case law. View "Fortney & Weygandt, Inc. v. Lewiston DMEP IX, LLC" on Justia Law

The Supreme Court affirmed the superior court's order concluding that because Jackson Lumber & Millwork Co. was both the mortgagee and the purchaser at the public sale of certain foreclosed property the fair market value of that property as established by an independent appraisal - rather than the value established by the highest bid at the public sale - was appropriate to determine the amount of any deficiency, holding that the superior court did not err.In ruling on Jackson Lumber's motion for approval of attachment and trustee process, the superior court concluded that Jackson Lumber was the "purchaser at the public sale" and that there was no recoverable deficiency given that the appraised value of the property exceeded the amount owed at the time of the foreclosure. At issue was whether Jackson Lumber was the "purchaser at the public sale" even though it did not ultimately acquire the property because it later assigned away its rights and never received the deed. The Supreme Court affirmed, holding that the superior court did not misinterpret the law or otherwise err or abuse its discretion in denying the motion for approval of attachment and trustee process as to the property. View "Jackson Lumber & Millwork Co. v. Rockwell Homes, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting the motion of Defendant, Plaintiff's former employer, to dismiss Plaintiff's disability discrimination and failure to accommodate claims as time-barred under the Maine Human Rights Act (MHRA), Me. Rev. Stat. 5, 4551-4634, holding that there was no error.Plaintiff brought this complaint alleging two counts under the Americans with Disabilities Act and two counts under the MHRA. A federal district court dismissed the first two counts and remanded the MHRA counts to the superior court. On remand, the superior court granted Defendant's motion to dismiss the remaining counts. The Supreme Judicial Court affirmed, holding that the action was not commenced within two years after the act of unlawful discrimination complained of, and therefore, the superior court properly determined that Plaintiff's disability discrimination claim was not commenced within he two-year statute of limitations under the MHRA. View "Berounsky v. Oceanside Rubbish, Inc." on Justia Law

The Supreme Judicial Court vacated the judgment of the probate court denying Mother's petition to modify or terminate an order of the superior court that transferred custody and guardianship of her child to the child's paternal grandmother and step-grandfather (together, Grandparents), holding that the probate court lacked subject matter jurisdiction.A Connecticut superior court granted the motion filed by the Connecticut Department of Children and Families to transfer custody and guardianship of the child to Grandparents, who lived in New Hampshire. After Mother, the child, and Grandparents had all moved to Maine, Mother filed a petition in the Hancock County Probate Court seeking to register and modify or terminate the Connecticut order. The probate court denied Mother's petition. The Supreme Judicial Court vacated the order below, holding that the probate court did not have subject matter jurisdiction to consider or adjudicate Mother's petition to modify a guardianship established in Connecticut's equivalent of a child protection matter. View "In re Guardianship by Stacey M." on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered in the superior court in favor of Defendant and dismissing Plaintiff's complaint alleging unlawful discrimination, retaliation, and discharge, holding that there was no error.In her complaint, Plaintiff alleged that Defendant, her former employer, violated the Whistleblowers’ Protection Act, Me. Rev. Stat. 26 831-840; the Maine Human Rights Act, Me. Rev. Stat. 5, 4551-4634; and Me. Rev. Stat. 26 570. The court granted Defendant summary judgment on all counts. The Supreme Judicial Court affirmed, holding (1) summary judgment in favor of Defendant was appropriate; and (2) the court did not err in denying Plaintiff's motion for relief pursuant to Me. R. Civ. P. 60(b)(4) because Defendant's electronic service did not violate Plaintiff's right to due process. View "Handlin v. Broadreach Public Relations, LLC" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered in the business and consumer court in favor of UIG, Inc. on Yankee Pride Transportation and Logistics, Inc.'s claims of negligence, breach of contract, and breach of fiduciary duty, holding that there was no genuine issue of material fact as to causation.On appeal, Yankee Pride argued that it had an implied contract with UIG based on the parties' relationship and that UIG breached that contract by failing to make timely efforts to renew Yankee Pride's policy. The Supreme Judicial Court disagreed, holding that Yankee Pride's failure to offer competent evidence of causation precluded a prima facie showing on any of its claims, whether they sounded in contract, tort, or breach of fiduciary duty. View "Yankee Pride Transportation & Logistics, Inc. v. UIG, Inc." on Justia Law

The Supreme Judicial Court vacated the summary judgment of the superior court concluding that the complaint brought by the Estate of Marion Sprague against Bankers Life and Casualty Company for breach of a home health insurance contract was barred by the applicable statute of limitations, holding that the facts established that the limitations period had not expired before the Estate filed suit.The Estate brought this complaint alleging breach of contract, detrimental reliance, impossibility of performance, quantum merit, and violation of Me. Rev. Stat. Ann. 24-A, 2155. Bankers Life filed a motion for summary judgment, arguing that the Estate's action was time-barred under Maine's six-year statute of limitations for civil actions. The Supreme Judicial Court vacated the summary judgment, holding that the Estate timely filed its complaint within the six-year limitations period. View "Estate of Sprague v. Bankers Life & Casualty Co." on Justia Law