Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the superior court's judgment dismissing with prejudice the foreclosure complaint filed by a Bank and affirmed the order of sanctions imposed on the Bank, holding that the complaint should have been dismissed without prejudice.On remand from the Supreme Judicial Court, the superior court granted the Bank's motion to voluntarily dismiss its foreclosure complaint without prejudice. Thomas Manning filed a motion for reconsideration of the court's order. After judicial settlement conferences, Manning filed a renewed motion for contempt against the Bank for its conduct at the settlement conference. Manning argued that the court should dismiss the foreclosure complaint with prejudice or, in the alternative, hold the Bank in contempt and impose sanctions. The court granted the motion for contempt and imposed sanctions, ordering the Bank to pay Manning's attorney fees and costs. The court then granted Manning's earlier motion for reconsideration and dismissed with prejudice the Bank's foreclosure complaint as a sanction for the Bank's conduct at the judicial settlement conference. The Supreme Judicial Court vacated the judgment in part, holding that the trial court abused its discretion in both granting Manning's motion for reconsideration and imposing sanctions on the Bank, including a dismissal with prejudice of the foreclosure complaint. View "U.S. Bank National Ass'n v. Manning" on Justia Law

In this dispute over a purported royalty fee, the Supreme Judicial Court vacated the superior court's order granting partial summary judgment in favor of InfoBridge, LLC on InfoBridge's claim for breach of contract, holding that the contract's royalty provision was ambiguous.Chimani and InfoBridge entered into a contract under which InfoBridge would create a software program. For this work, Chimani was to pay InfoBridge scheduled payments. The contract also contained a royalty provision requiring Chimani to pay InfoBridge royalties. InfoBridge later filed a complaint against Chimani alleging, inter alia breach of contract. InfoBridge then moved for partial summary judgment on its breach of contract claim, arguing that the royalty provision unambiguously required Chimani to pay InfoBridge 14.5 percent of Chimani's net revenue from the program, up to a total royalty fee of $150,000. The court granted the motion for summary judgment and denied Chimani's cross-motion for summary judgment on its equitable estoppel affirmative defense on the grounds that Chimani waived the equitable estoppel issue. The Supreme Court affirmed in part and vacated in part the judgment below, holding (1) Chimani waived its equitable estoppel defense; but (2) the royalty provision was ambiguous, and the summary judgment record did not permit a determination of its meaning as a matter of law. View "InfoBridge, LLC v. Chimani, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court granting Pat Doe's request for a ten-year extension of a protection from abuse order against Donald McLean, holding that the district court did not abuse its discretion.On appeal, Doe argued that the district court erred by refusing to hold a hearing on the issue of whether abuse had occurred and in declining to hold a hearing on her request for attorney fees. The Supreme Judicial Court affirmed, holding (1) the court's rejection of Doe's request to treat her motion to extend as a motion to modify that included a finding of abuse was well within the court's discretion; and (2) the court's decision not to award attorney fees was not an abuse of its discretion. View "Doe v. McLean" on Justia Law

The Supreme Judicial Court dismissed as moot Appellant's appeal from a judgment entered by the superior court ordering the involuntary medical treatment of Appellant, holding that because Appellant was no longer subject to the court's involuntary treatment order, this appeal was moot.Appellant was arrested and charged with burglary and theft by unauthorized taking. While Appellant was in preconviction detention at the mental health unit of the Maine State Prison (MSP) the Department of Corrections filed an application pursuant to Me. Rev. Stat. 34-A, 3049 seeking the involuntary medication of Appellant. The court entered an ex parte order granting the emergency application and permitting the immediate medication of Appellant for a period of 120 days. Appellant appealed. The Supreme Judicial Court dismissed the appeal as moot, holding that because Appellant was no longer at the mental health unit of the MSP and the involuntary treatment order had expired, the appeal was moot and no exceptions to the mootness doctrine applied. View "In re Involuntary Treatment of K." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court partitioning real property in Kittery held by Toralf Strand and Sabrina Velandry as tenants in common, holding that the court did not err in dividing equally the value of the property after crediting Strand with the amount his spent for insurance, repairs, improvements, and real estate taxes.In 2014, Strand signed a purchase and sale agreement solely in his name to buy the house and included Velandry on the deed as a tenant in common. After the parties separated, Strand filed a complaint for equitable partition of the property pursuant to 14 Me. Rev. Stat. 6051(7). The court awarded Strand the amount his spent on insurance, improvements, repairs, and real estate taxes and then divided the property's remaining appraisal value equally between Strand and Velandry. The Supreme Judicial Court affirmed, holding (1) because the court found that Strand did not condition Velandry's interest as a tenant in common on her agreement to pay Strand half of the property's purchase price, the court did not err in applying the presumption of equal ownership and entering judgment accordingly; and (2) the court did not clearly err in disallowing certain of Strand's claimed credits and set-off. View "Strand v. Velandry" on Justia Law

The Supreme Judicial Court dismissed as moot this appeal from the decision of the superior court dismissing Appellant's petition against the Maine Department of Corrections for failure to serve the Department pursuant to Me. Rev. Stat. 5, 11003(1), holding that events in the superior court had overtaken this appeal, rendering it moot.After Appellant filed this action, the trial court, treating the action as a petition for review of agency action, issued Appellant an order requiring him to show cause why his appeal should not be dismissed for failure to serve the Department. The court ultimately dismissed the petition for insufficient service of process. After Appellant's appeal was docketed, Appellant filed a motion asserting that the Department had acknowledged receipt of process. The court then negated its dismissal of Appellant's action. Therefore, the Supreme Court dismissed the appeal as moot. View "Paquette v. Department of Corrections" on Justia Law

The Supreme Judicial court vacated the judgment of the trial court denying Defendant's petition for post-conviction review, holding that Defendant must receive a new hearing on his petition.Defendant pleaded guilty of trafficking in prison contraband. Defendant later filed a petition for post-conviction review alleging ineffective assistance by his plea counsel. The court held a hearing and announced that it would grant Defendant's petition. The court began to issue that decision from the bench, but an interruption led the court to resume the hearing. The court then proceeded to deny the petition. The Supreme Court reversed, holding that, under the circumstances of this case, the process at Defendant's hearing irredeemably tarnished the appearance of fairness in the proceeding. View "Evans v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for unlawful sexual contact and domestic violence assault, holding that the prosecutor did not commit misconduct and that the trial court did not abuse its discretion in denying Defendant the opportunity to call as a witness the district attorney's victim witness advocate (VWA).On appeal, Defendant argued that the prosecutor committed multiple instances of misconduct and that the trial court abused its discretion in denying him the opportunity to call the VWA to testify. The Supreme Judicial Court affirmed, holding (1) even if a statement made by the prosecutor was improper, it did not amount to harmful error; (2) the trial court did not abuse its discretion when it denied Defendant's motion for a new trial; and (3) the trial court did not abuse its discretion in denying Defendant's request that the VWA testify. View "State v. Sholes" on Justia Law

The Supreme Judicial Court affirmed the decision of the Maine Public Utilities Commission granting Central Maine Power Company's (CMP) petition for a certificate of public convenience and necessity (CPCN) for the construction and operation of the New England Clean Energy Connect (NECEC) project, holding that the Commission followed the proper procedure and that there was sufficient evidence in the record to support the Commission's findings.In 2017, CMP filed a petition with the Commission for a CPCN for the NECEC project, a 145-mile transmission line. The Commission voted to grant CMP a CPCN for the construction and operation of the NECEC project. The Supreme Judicial Court affirmed, holding (1) the Commission did not commit legal error when it decided that CMP was not required to file the results of a third-party investigation into nontransmission alternatives; (2) the Commission did not err in its construction and application of Me. Rev. Stat. 35-A, 3132(6); and (3) the Commission did not abuse its discretion in approving a stipulation between the parties requiring the project to provide myriad benefits to ratepayers and the State as conditions to the recommended Commission approval of the stipulated findings and issuance of the CPCN. View "NextEra Energy Resources, LLC v. Maine Public Utilities Commission" on Justia Law

The Supreme Judicial Court affirmed the judgment of foreclosure entered by the district court in favor of U.S. Bank, holding that the district court did not err in concluding that U.S. Bank had standing to foreclose.U.S. Bank filed a complaint for foreclosure. At a hearing, the court admitted, over Jim Gordon's objection, a copy if a 2016 "Ratification of Assignment" stating that Mortgage Electronic Registration Systems, Inc., as nominee for EquiFirst Corporation, assigned the mortgage in this case to U.S. Bank. The court ultimately concluded that U.S. Bank had standing to foreclose pursuant to the 2016 ratification and entered a judgment of foreclosure in favor of U.S. Bank. The Supreme Judicial Court affirmed, holding (1) the court did not abuse its discretion by admitting the copy of the 2016 ratification; and (2) the court did not err in concluding that U.S. Bank had standing. View "U.S. Bank National Association v. Gordon" on Justia Law