Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court on consolidated Rule 80C appeals from the decision of the Maine Labor Relations Board (MLRB) on the School Administrative District 3 Education Association MEA/NEA’s (the Association) prohibited practice complaint, holding that the MLRB did not err when it held that the 120-day notice provision in Me. Rev. Stat. 26, 965(1) applied to the request for impact bargaining in this case.The Association filed a prohibited practice complaint with the MLRB against the Board of Directors of Regional School Unit 3 (the School Board), alleging that the School Board violated Me. Rev. Stat. 26, 964(1)(E) and 965(1) when it refused to participate in mediation and fact-finding procedures with respect to the effect of a new bus system. The MLRB determined that the Association failed to comply with the 120-day notice requirement in section 965(1) by failing to participate in fact-finding concerning the impact of the new busing system. The superior court affirmed. The Supreme Judicial Court affirmed, holding that the MLRB did not clearly err in finding that the Association did not provide adequate notice to satisfy section 965(1). View "SAD 3 Education Ass’n v. RSU 3 Board of Directors" on Justia Law

The Town of Steuben’s taking of an interest in Rogers Point Road by eminent domain pursuant to Me. Rev. Stat. 23, 3023 was constitutional because it arose from a public exigency and was for public use.Bayberry Cove Children’s Land Trust filed a complaint challenging the Town’s determinations that the taking of an interest in the road was supported by a public exigency and that the use of the road was public. The superior court affirmed the Town’s decision. The Supreme Judicial Court affirmed, holding (1) there was a rational basis in the record to support the Town’s finding of a public exigency; (2) evidence in the record, confirmed by the Trust’s characterization of the public’s right to use the road, definitively established that the interest in the road was taken for a public use; and (3) therefore, the taking was constitutional. View "Bayberry Cove Children's Land Trust v. Town of Steuben" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the Town of Yarmouth Planning Board’s approval of a site plan application by Verizon Wireless to install wireless communication equipment on a tower and site owned by the Yarmouth Water District, holding that the Board did not err by concluding that Verizon’s application complied with the relevant provisions of Yarmouth’s Zoning Ordinance. Contrary to Appellants’ contentions on appeal, the Supreme Court held (1) the Yarmouth Water District site was not subject to a presumption of unsuitability because the relevant article of the Ordinance applies only to new-tower-construction applicants; and (2) substantial evidence in the record supported the Board’s findings that Verizon presented sufficient evidence that it investigated other technically feasible sites and that none was available. View "Olson v. Town of Yarmouth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the Town of Yarmouth Planning Board’s approval of a site plan application by Verizon Wireless to install wireless communication equipment on a tower and site owned by the Yarmouth Water District, holding that the Board did not err by concluding that Verizon’s application complied with the relevant provisions of Yarmouth’s Zoning Ordinance. Contrary to Appellants’ contentions on appeal, the Supreme Court held (1) the Yarmouth Water District site was not subject to a presumption of unsuitability because the relevant article of the Ordinance applies only to new-tower-construction applicants; and (2) substantial evidence in the record supported the Board’s findings that Verizon presented sufficient evidence that it investigated other technically feasible sites and that none was available. View "Olson v. Town of Yarmouth" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for operating under the influence (OUI), operating after habitual offender revocation, and driving to endanger, entered by the trial court after a jury trial. The court held (1) the trial court did not abuse its discretion in denying Defendant’s motion for a mistrial after an officer testified that Defendant was on probation at the time of his arrest; (2) the prosecutor did not commit misconduct; and (3) the trial court did not err by not instructing the jury on the competing harms justification as to the charges of operating under the influence and driving to endanger. View "State v. Nobles" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part the amended judgment entered in the district court granting Edward Manter’s motion to modify and amending the parties’ 2008 divorce judgment as amended. The Supreme Court held (1) the district court did not abuse its discretion or err when it modified the parents’ rights of contract; (2) the district court did not abuse its discretion when it denied Manter’s motion for amended or additional findings; and (3) because the record was devoid of evidence regarding interim child support payments, it could not be determined whether the district court erred when it determined that Master was nearly $11,000 in arrears of his child support obligation. The Supreme Court remanded the matter to the district court for further proceedings. View "Boyd v. Manter" on Justia Law

Me. Rev. Stat. 39-A, 221 entitles an employer to a credit for workers’ compensation benefits previously paid for the same liability period when the employee was also receiving Social Security retirement benefits.Plaintiff was paid total incapacity workers’ compensation benefits by his employer, Interstate Brands International, after he sustained injuries in an initial workplace accident. For three years, Plaintiff collected Social Security retirement benefits while receiving the full amount of the workers’ compensation benefits. When Interstate learned that Plaintiff was receiving Social Security benefits, it sought a credit against the ongoing incapacity payments pursuant to section 221. A hearing officer determined that Interstate was entitled to a credit of nearly $25,000. The Workers’ Compensation Appellate Division vacated the decree, concluding that section 221 does not allow a reduction based on incapacity overpayments made in the past. The Supreme Judicial Court vacated the Appellate Division’s decision, holding that Interstate was entitled to a credit for incapacity benefit overpayments made to Plaintiff during the same period when he received Social Security retirement benefits. View "Urrutia v. Interstate Brands International" on Justia Law

Me. Rev. Stat. 39-A, 221 entitles an employer to a credit for workers’ compensation benefits previously paid for the same liability period when the employee was also receiving Social Security retirement benefits.Plaintiff was paid total incapacity workers’ compensation benefits by his employer, Interstate Brands International, after he sustained injuries in an initial workplace accident. For three years, Plaintiff collected Social Security retirement benefits while receiving the full amount of the workers’ compensation benefits. When Interstate learned that Plaintiff was receiving Social Security benefits, it sought a credit against the ongoing incapacity payments pursuant to section 221. A hearing officer determined that Interstate was entitled to a credit of nearly $25,000. The Workers’ Compensation Appellate Division vacated the decree, concluding that section 221 does not allow a reduction based on incapacity overpayments made in the past. The Supreme Judicial Court vacated the Appellate Division’s decision, holding that Interstate was entitled to a credit for incapacity benefit overpayments made to Plaintiff during the same period when he received Social Security retirement benefits. View "Urrutia v. Interstate Brands International" on Justia Law

In this divorce action, the district court failed to set forth adequate findings on the issues raised by Appellant in a Me. R. Civ. P. 52 motion regarding spousal support and property classification.On appeal from a divorce judgment, Appellant argued that the district court erred when it failed to classify certain real estate as marital or nonmarital and abused its discretion in its award of spousal support. The Supreme Court held (1) the denial of Appellant’s Me. R. Civ. P. 52 motion regarding the property classification was an abuse of discretion because the court neither set forth adequate findings on this issue in its judgment nor made findings on the issue raised by Appellant in his Rule 52 motion; and (2) the court abused its discretion when it denied Appellant’s Rule 52 motion as it pertained to the spousal support award. View "Mooar v. Greenleaf" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court denying the State’s motion to reconsider the court’s order dismissing, with prejudice, thirteen of the State’s fifteen counts against Defendant as a sanction for an alleged discovery violation. Although the trial court noted that the discovery violation was not the result of any bad faith or improper effort, it determined that dismissal was the appropriate sanction. The Supreme Judicial Court remanded the case to the trial court, holding that the court erred as a matter of law by concluding that the State committed a discovery violation, and therefore, it had no authority to sanction the State. View "State v. Hassan" on Justia Law