Articles Posted in Maine Supreme Judicial Court

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The Supreme Judicial Court vacated the judgment of the district court dismissing Appellant's complaint seeking to be determined a de facto parent of Appellee's adopted child, holding that the district court erred in dismissing this case for lack of standing. The district court dismissed Appellant's complaint for lack of standing. On appeal, Appellant argued that the district court abused its discretion in refusing to hold a hearing to determine disputed facts and in concluding that Appellee's refusal to allow Appellant to adopt the child was dispositive of the issue of whether Appellee acknowledged or behaved as though Appellant was a parent to the child. The Supreme Judicial Court remanded the case, holding that the court's treatment of the single fact of Appellee's refusal to allow Appellant to adopt as dispositive in the standing analysis constituted an error of law, and the court should have held a hearing to determine disputed facts regarding the issue of standing. View "Young v. King" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court dismissing Plaintiffs’ complaint but vacated the order imposing sanctions on Plaintiffs, holding that the superior court abused its discretion in imposing sanctions. After the Town of Arundel Planning Board denied an application to renew a conditional use permit submitted by Dubois Livestock Inc., Plaintiffs - Marcel Dubois and Sol Fedder - filed this complaint against the Town, individual members of the Planning Board, and the Town Planner, alleging that the Planning Board met at an illegal executive session or sessions. The superior court dismissed the complaint for lack of standing and failure to state a claim. The superior court then granted Defendants attorney fees and costs. The Supreme Judicial Court held (1) the superior court did not err in dismissing the complaint because Plaintiffs lacked standing to pursue a Me. R. Civ. P. 80B complaint, and the complaint failed to state a claim under the Freedom of Access Act, Me. Rev. Stat. 1, 400-414; and (2) the superior court’s imposition of sanctions pursuant to Me. R. Civ. P. 11 was an abuse of discretion. View "Dubois v. Town of Arundel" on Justia Law

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The Supreme Judicial Court vacated the summary judgment entered by the superior court in favor of Defendant on Plaintiff’s complaint asserting that Defendant was negligent and had caused Plaintiff economic harm, holding that claim preclusion cannot operate to bar a subsequent suit brought in district or superior court by a person who was not an actual party in a previous small claims action. A third party driving a vehicle owned by Plaintiff was involved in a collision with a vehicle driven by Defendant. In a small claims matter, Defendant sued the third party, and the district court found the third party was negligent. Plaintiff then brought this action against Defendant. The superior court applied the doctrine of res judicata to the earlier small claims judgment and determined that the earlier judgment conclusively resolved the issue of which driver was at fault. The Supreme Court vacated the judgment, holding that, because of the unique limitations of small claims procedure, claim preclusion did not bar this suit by a person who was, at most, in privity with the defendant in the small claims case. View "Ring v. Leighton" on Justia Law

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In this dispute over the location of the boundary between the land of Appellees and the land of Appellants, the Supreme Judicial Court affirmed the judgment of the superior court declaring the location of that boundary line, holding that the superior court did not err or abuse its discretion. On appeal, Appellants generally challenged the discretionary decisions made by the trial court in its management of the proceeding. The Supreme Judicial Court denied the challenges, holding that, contrary to Appellants’ contentions, the trial court did not err or abuse its discretion either in its case management orders or in its findings and conclusions. View "Gammon v. Boggs" on Justia Law

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The Supreme Judicial Court dismissed this appeal challenging the promulgation of a final rule by the Public Utilities Commission, holding that this Court does not have original jurisdiction over appeals from administrative rulemaking proceedings. Appellants, including the Conservation Law Foundation, the Industrial Energy Consumers’ Group, ReVision Energy, LLC, and the Natural Resources Council of Maine, argued, among other things, that, in promulgating the rule at issue, the Commission violated several provisions of the Maine Administrative Procedure Act, that the rule violated statutory ban on exit fees, and that the rule unjustly discriminated. The Commission argued that Me. Rev. Stat. 35-A, 1320 does not authorize appeals to the Law Court when the Commission acts pursuant to its rulemaking authority. The Supreme Judicial Court agreed, holding that any appeal from Commission rulemaking proceedings must be brought originally in the Superior Court. View "Conservation Law Foundation v. Public Utilities Commission" on Justia Law

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In this interlocutory appeal, the Supreme Judicial Court remanded the matter without reaching the merits of the appeal, holding that the discovery order challenged on appeal was now a nullity and did not govern future proceedings in this case and that no exception to the final judgment applied. Appellants appealed from an order of the superior court granting Appellee’s motion to compel them to produce in discovery certain patient medical records that the court found to relevant to Appellees' notice of claim asserting medical negligence. The Supreme Judicial Court held (1) given the unusual procedural posture presented in this case, the discovery order was a nullity without legal force or effect and did not govern future proceedings in this case; and (2) no exception to the final judgment rule applied that would require the Court to reach the merits of the parties’ arguments below. View "McCain v. Vanadia" on Justia Law

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The “prisoner mailbox rule” applies when a prisoner is forced to rely on the Department of Corrections to ensure that his Me. R. Civ. P. 80C petition is filed, that prisoner places the petition into the control of the Department, and the Department fails timely to deliver the petition to the clerk of court. Petitioner signed a petition pursuant to Me. Rev. Stat. 5, 11002 for judicial review of a Department decision finding that he had committed a disciplinary infraction. The State moved to dismiss the petition for failure to state a claim, arguing that because the clerk of court received Petitioner’s petition one day outside of the thirty-day statutory window, the superior court lacked jurisdiction over the matter. Petitioner urged the superior court to apply the prison mailbox rule, whereby the court would consider the petition filed on the date Petitioner deposited it with prison officials for forwarding to the clerk of court rather than the day it was received by the clerk of court. The court granted the State’s motion to dismiss. After setting forth the circumstances above under which the prisoner mailbox rule applies the Supreme Judicial Court adopted the prison mailbox rule for any unrepresented prisoner under the circumstances of this case, vacated the judgment, and remanded to the superior court for reinstatement of the Rule 80C petition. View "Martin v. Department of Corrections" on Justia Law

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The Supreme Judicial Court affirmed a summary judgment entered in the Business and Consumer Docket in favor of Copay Italia S.p.A. on Puritan Medical Products Company’s claim that Copay violated Maine’s Actions for Bad Faith Assertion of Patent Infringement statute, Me. Rev. Stat. 14, 8701-8702, holding that Puritan’s claim was preempted by federal patent law. Although the lower court granted summary judgment for Copan after finding no genuine issues of material fact and determining that Copay was entitled to judgment as a matter of law, Copan filed a cross-appeal challenging the court’s conclusion that Puritan’s claim was not preempted by federal law. The Supreme Judicial Court affirmed, holding (1) in its preemption analysis, the trial court conflated the test for federal preemption with the test for federal jurisdiction; and (2) federal patent law preempted Puritan’s state law claim, and therefore, summary judgment in favor of Copay was properly granted on that basis. View "Puritan Medical Products Co. v. Copan Italia S.p.A." on Justia Law

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The Supreme Judicial Court dismissed this interlocutory appeal brought by Defendants challenging the superior court’s denial of their motion to seal or strike, holding that Defendants did not demonstrate the irreparable harm necessary for appellate review of the court’s interlocutory order. Plaintiff, the respondent in an attorney discipline proceeding, filed a complaint against Judge Marian Woodman and Judge Nancy Carlson based on their actions and involvement in the disciplinary proceeding. Defendants filed motions to dismiss the complaint and sought imposition of sanctions. After Plaintiff filed a response to the motions the judges filed a motion to seal or strike certain paragraphs of Plaintiff’s response, in which Plaintiff made assertions about the judges and a family member of one of them. The superior court denied the motion. The judges appealed. The Supreme Judicial Court dismissed the appeal, holding that the appeal did not fall within an exception to the final judgment rule. View "Carey v. Maine Board of Overseers of the Bar" on Justia Law

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The Supreme Judicial Court vacated the judgment of the superior court dismissing Petitioner’s complaint seeking review of a disciplinary decision of the Department of Corrections. In dismissing the petition, the superior court entered sua sponte a decision stating that the case was dismissed for lack of jurisdiction. The record was otherwise devoid of any indication of the basis on which the court concluded that it lacked jurisdiction. The Supreme Judicial Court held that no jurisdictional defect was apparent from the record and remanded the matter to the superior court for the court to act on Petitioner’s application to proceed without payment of fees. View "Anctil v. Department of Corrections" on Justia Law