Articles Posted in Maine Supreme Judicial Court

by
The Supreme Judicial Court affirmed the judgment of the superior court in favor of Defendant on Plaintiffs’ defamation action. The trial court concluded that Plaintiffs failed to make the necessary prima facie showing that Defendant acted with actual malice. The Supreme Judicial Court held that no genuine issue of material fact existed and that Defendant was entitled to summary judgment because Plaintiffs failed to produce any evidence of the sort required to establish actual malice - such as evidence of Defendant’s negligence, motive, and intent - and, therefore, Plaintiffs could not prevail at trial. View "Plante v. Long" on Justia Law

by
Alan Miller, acting “individually and in the right of” and for the benefit of SAM Miller, Inc. (SMI), filed a second amended complaint against Miller’s Lobster Company, Inc. (MLC), Steve Miller, and Mark Miller (collectively, the Millers) seeking injunctive relief and damages arising out of the lease of wharf property by SMI to MLC. The court granted the Millers’ and SMI’s motions for summary judgment, concluding that Alan Miller’s claims were barred on limitations grounds. The Supreme Judicial Court affirmed, holding that Alan’s action was barred by the applicable statute of limitations and that Alan did not meet his burden to demonstrate a genuine issue of material fact as to whether the limitations period was nevertheless tolled or otherwise inapplicable. View "Miller v. Miller" on Justia Law

by
Dawn Haskell and Martin Witham (together, Plaintiffs) filed a complaint against Grover Bragg and Donald York (together, Defendants), asserting a claim for negligence against Defendants. Bragg did not timely file an answer after being served and did not otherwise appear in or defend in the matter. The clerk entered a default against Bragg. The court awarded compensatory damages based on the allegations in the complaint. The Supreme Judicial Court affirmed, holding that although the trial court erred when it considered evidence of comparative negligence, the error was harmless because the court found that Plaintiffs were not negligent. View "Haskell v. Bragg" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the superior court finding that the tortfeasor who injured Appellants in a motor vehicle accident was not an underinsured driver pursuant to Maine’s underinsured motorist (UM) statute, and therefore, there was no gap in coverage requiring State Farm Mutual Automobile Insurance Company to pay UM benefits under two policies issued to Appellants. The court held that because Appellants recovered far more from the tortfeasor’s insurers than the maximum amount of UM coverage provided by the State Farm policies, they surpassed the same recovery that would have been available had the tortfeasor been insured to the same extent. Therefore, there was no UM gap that State Farm was responsible to cover. View "Wallace v. State Farm Mutual Automobile Insurance Co." on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the district court finding Brian Beaulieu Jr. liable to Greg and Victoria Goodwill for having made fraudulent and negligent misrepresentations about certain amenities in a house that he sold to them and awarding damages. On appeal, Beaulieu asserted that, pursuant to Me. Rev. Stat. 14, 163, he was entitled to a setoff against the amount of damages he was ordered to pay based on the Goodwills’ settlement with the real estate agency that listed his house. The Supreme Judicial Court disagreed, holding that the district court did not err by declining to reduce the damage award by the amount of the settlement between the Goodwills and the real estate agency that listed Beaulieu’s house because Beaulieu was not entitled to the setoff as a matter of law. View "Goodwill v. Beaulieu" on Justia Law

by
Arthur Murdock, a police officer, was attempting to cut across two eastbound lanes of traffic and into a parking lot when his police cruiser was struck by another vehicle traveling in the outside eastbound lane from behind where Martin Thorne’s car was stopped in traffic. Murdock filed a four-count complaint alleging, as relevant to this appeal, negligence claims against Thorne and underinsured motorist (UM) claims against his employer, the Maine department of Public Safety (DPS). The superior court granted summary judgment for DPS and Thorne. The Supreme Judicial Court affirmed, holding (1) because Murdock failed to make a prima facie showing that Thorne’s “wave-on” gesture was the proximate cause of his injuries, Thorne was entitled to summary judgment on Murdock’s negligence claim; and (2) because Murdock’s UM claim against DPS was predicated upon his negligence claim against Thorne, summary judgment was properly granted in favor of DPS. View "Murdock v. Thorne" on Justia Law

by
The Supreme Judicial Court vacated the judgment of the district court dismissing Plaintiff’s fraudulent transfer complaint as having been filed outside the applicable statute of limitations, holding that the court should have treated the motion to dismiss as a motion for summary judgment. Plaintiff brought a complaint against Defendants alleging violations of the Uniform Fraudulent Transfer Act. Defendants moved to dismiss the complaint on the ground that the applicable six-year statute of limitations ran one day before the date that Plaintiff’s complaint was filed. The district court granted the motion to dismiss. The Supreme Judicial Court held that Plaintiff’s submission of extrinsic evidence converted the motion to dismiss to a motion for summary judgment, and accordingly, the court erred in failing to proceed with the summary judgment process. View "Acadia Resources, Inc. v. VMS, LLC" on Justia Law

by
Plaintiffs filed a complaint against Defendant alleging tortious interference with an expected inheritance and breach of contract. The superior court granted Defendant’s motion to dismiss pursuant to Me. R. Civ. P. 12(b)(6), concluding (1) the tortious interference with an expected inheritance count did not satisfy the rule that a promise to take a future action will not support an action for fraud and did not state the nature or scope of the fraud allegations with particularity, and (2) the contract alleged in the breach of contract count did not satisfy the statute of frauds. The Supreme Judicial Court vacated the judgment dismissing Plaintiffs’ complaint and remanded for entry of dismissal without prejudice, holding that the issues raised by the complaint were not ripe for judicial review. View "Johnson v. Crane" on Justia Law

by
After this case was returned from the federal courts to a Florida superior court’s jurisdiction, only Plaintiff’s claims for defamation and false light invasion of privacy remained. Plaintiff, a town official for the Town of Raymond, filed suit against a town selectman, alleging Defendant had made various false statements to the sheriff’s office about Plaintiff’s alcohol for the purpose of humiliating and harassing Plaintiff. The superior court granted Defendant’s special motion to dismiss both remaining causes of action on anti-SLAPP grounds. The Supreme Judicial Court affirmed, holding that Plaintiff failed, as a matter of law, to meet his prima facie burden on opposing Defendant’s special motion to dismiss, and therefore, the superior court correctly dismissed the remaining claims. View "Desjardins v. Reynolds" on Justia Law

by
Appellant appealed from the superior court’s post-judgment order awarding her attorney fees in the amount of $8,000 after a jury found Appellee liable for illegal eviction and wrongful use of civil proceedings. Appellant had requested nearly $60,000 in attorney fees. The Supreme Court affirmed, holding that the superior court did not apply an improper standard in evaluating Appellant’s request for attorney fees and that the court’s ultimate fee award was not an abuse of discretion. The court reviewed the award of attorney fees pursuant to Me. Rev. Stat. 14, 6014(2)(B) for an abuse of discretion and according the trial court substantial deference. View "Sands v. Thomas" on Justia Law