Justia Civil Procedure Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court affirmed the judgment of the district court in favor of John Bump on Wells Fargo Bank's foreclosure complaint, holding that the court did not err by concluding that a 2015 order dismissing without prejudice Wells Fargo's earlier action seeking foreclosure on the same mortgage did not vacate the final judgment in Bump's favor that had been entered in 2013 in that same case.Wells Fargo filed a foreclosure action in the district court in 2009. After a bench trial in 2013, the court entered judgment on the merits in favor of Bump. In 2015, the court granted Wells Fargo's motion to dismiss the 2009 action without prejudice. In 2016, Wells Fargo filed a new action to foreclose on the same mortgage. In 2020, the court entered judgment in favor of Bump, stating that it took notice of the 2013 final judgment and concluding that the 2015 order of dismissal without prejudice did not operate to vacate that judgment. The court then determined that Wells Fargo's entire claim was barred by res judicial given the 2013 judgment. The Supreme Judicial Court affirmed, holding that the district court (1) properly concluded that the preclusive effect of the 2013 judgment barred the present action; and (2) did not abuse its discretion in taking judicial notice of the prior judgment. View "Wells Fargo Bank v. Bump" on Justia Law

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In this challenge to the superior court's judgment on a petition for judicial review challenging a decision of the Secretary of State the Supreme Judicial Court held that execution of the judgment was automatically stayed on appeal.The superior court vacated the Secretary of State's determination that insufficient signatures had been collective to place on the November 2020 ballot a people's veto of An Act to Implement Ranked-choice Voting for Presidential Primary and General Elections in Maine. Appellants moved to stay execution of the judgment pending their appeals to the Supreme Judicial Court. The Supreme Judicial Court dismissed both motions to stay as moot, holding that execution of the judgment was automatically stayed upon appeal. View "Jones v. Secretary of State" on Justia Law

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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

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The Supreme Judicial Court dismissed Kathleen Flanders' appeal from an interlocutory order entered by the district court denying Flanders' motion to disqualify Attorney Eric Morse from representing Fern Gordon in a personal injury case, holding that allowing the appeal of this interlocutory order to proceed would not be in the interest of judicial economy.Gordon, the defendant in Flanders' personal injury suit, retained Attorney Morse to defend her. While the lawsuit against Gordon was pending, Flanders was injured in a motor vehicle accident. Flanders sought legal assistance from a partner of Attorney Morse, who continued to represent Gordon in the personal injury suit. Flanders moved to disqualify Attorney Morse, but the court denied the motion. Flanders appealed. The Supreme Judicial Court dismissed the appeal, holding that none of the exceptions to the final judgment rule applied in this case. View "Flanders v. Gordon" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court affirming a small claims judgment entered in the district court against Roger and Melody Vallee and in favor of Manon Cote and Sylvain Theriault subject to a modest reduction in the amount of damages awarded to Cote and Theriault, holding that the Vallees were not entitled to relief on their claims.Cote and Theriault filed a statement of claim in the district court seeking a small claims judgment against the Vallees for $6,000. The district court entered judgment in favor of Cote and Theriault. On appeal, the parties invited and consented to the superior court deviating from the practice for small claims appeals as specified in the court's rules. After a bench trial, the superior court remanded the matter for the entry of a judgment in favor of Cote and Theriault in the reduced amount of $5,196.84. The Vallees appealed, contending that the superior court should not have allowed them to waive their request for a jury trial. The Supreme Judicial Court affirmed, holding that the Vallees' strategic choices to deviate from procedural requirements for small claims appeals could not be undone on an appeal from the resulting judgment. View "Cote v. Vallee" on Justia Law

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The Supreme Judicial Court vacated the judgment of the district court dismissing Appellant's compliant alleging revocation of acceptance and breach of warranty as time-barred, holding that the court relied upon facts contained in documents that exceeded the scope of the facts that may be considered by the court in the context of a motion to dismiss.Appellant brought this action alleging claims with respect to a bicycle frame that he purchased that was manufactured by Independent Fabrication, Inc. The district court dismissed the complaint as barred by the four-year statute of limitations set forth in Me. Rev. Stat. 11, 2-725. The Supreme Judicial Court vacated the order of dismissal on procedural grounds and remanded for further proceedings, holding that the court's consideration of matters outside the pleadings in granting Independent's motion to dismiss was in error. View "Greif v. Independent Fabrication, Inc." on Justia Law

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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