Articles Posted in Maine Supreme Judicial Court

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The Supreme Judicial Court affirmed the district court’s grant of partial summary judgment in favor of Avis Rent A Car System, LLC on Avis’s claim for breach of contract but vacated the court’s award of damages. Defendant, a Maine resident, rented a car from an Avis location in Las Vegas, Nevada. The vehicle was damaged when it was involved in an accident in Las Vegas. When Defendant refused to pay for the damages, Avis filed a complaint against Defendant, alleging breach of connect and negligence. The district court concluded that Avis was entitled to partial summary judgment on the breach of contract claim as a matter of law. After an evidentiary hearing, the court granted Avis its requested amount of $15,342 and also awarded attorney fees and costs. The Supreme Judicial Court reversed in part, holding that partial summary judgment as to liability was correctly granted but because Avis presented no admissible evidence as to the amount of damages, it failed to prove it was entitled to the damages awarded to it. The Court then remanded the case for an award of nominal damages in accordance with Nevada law. View "Avis Rent A Car System, LLC v. Burrill" on Justia Law

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Maine attorneys must obtain a client’s informed consent regarding the scope and effect of any contractual provision that prospectively requires the client to submit malpractice claims against those attorneys to arbitration. The Supreme Judicial Court affirmed the judgment of the superior court denying Bernstein, Shur, Sawyer & Nelson, P.A.’s (Bernstein) motion to compel arbitration in a legal malpractice claim filed against it. The superior court concluded that Bernstein failed to obtain informed consent from Susan Snow, its client, to submit malpractice claims to arbitration and that federal law does not preempt a rule requiring attorneys to obtain such informed consent from their clients. The Supreme Judicial Court affirmed, holding that the superior court did not err in concluding that (1) Bernstein’s failure to obtain informed consent from Snow regarding an arbitration provision rendered that provision unenforceable as contrary to public policy; and (2) the Federal Arbitration Act does not preempt a requirement that attorneys obtain informed consent from their clients before contracting to submit disputes to arbitration. View "Snow v. Bernstein, Shur, Sawyer & Nelson, P.A." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court granting Matthew Eastwick’s application to confirm an arbitration award and denying Cate Street Capital, Inc.’s competing motion to vacate that award after concluding that the parties had agreed to arbitrate any disputes arising from a settlement agreement. The Supreme Judicial Court held (1) the agreement contained clear contractual language of the parties’ intent to submit disputes to the mediator for binding arbitration; and (2) although the parties’ confidentiality had been compromised by the litigation, the court’s judgment incorporated the final agreement without ordering acceleration of those payments not yet due and without modifying any of its terms, including the agreement’s confidentiality provision. View "Eastwick v. Cate Street Capital, Inc." on Justia Law

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The district court did not err in finding that Portfolio Recovery Associates, LLC (PRA) had met its burden of proof and by admitting PRA’s exhibits into evidence. The district court entered judgment in a small claims proceeding finding Max Bickford liable on debt that PRA had purchased from a prior creditor. The superior court affirmed. The Supreme Judicial Court affirmed, holding (1) the district court did not err by finding that PRA had met its burden of proof to establish its ownership of Bickford’s debt; and (2) the district court did not err by admitting PRA’s affidavits into evidence where the affidavits and other documents fell within the general grant of admissibility created in Maine Rules of Small Claims Procedure rule 6(b) and where none of that rule’s grounds for exclusion applied in this case. View "Portfolio Recovery Associates, LLC v. Bickford" on Justia Law

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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

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In this dispute concerning the rights and obligations of Appellants pursuant to a pipeline capacity agreement they had with Appellee, the Supreme Judicial Court affirmed the judgment of the business and consumer docket denying Appellants’ application to vacate several arbitration awards pursuant to Me. Rev. Stat. 14, 5938(1)(C). The court held that, contrary to Appellants’ argument on appeal, the arbitrator did not exceed his authority pursuant to the statute because the arbitration awards did not directly contradict the language of the agreement or constitute a manifest disregard for the terms of the agreement. View "XPress Natural Gas, LLC v. Woodland Pulp, LLC" on Justia Law

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John F. Murphy Homes, Inc. operates a private school that offers medical services that are paid for by MaineCare, a State Medicaid program. The State pays one-third of costs for MaineCare, a contribution commonly referred to as the Seed. In 2013, Murphy Homes filed a complaint that, as construed by the trial court, stated claims for breach of contract, quantum meruit, and an equitable claim for unjust enrichment or equitable estoppel, alleging that it was owed $7.5 million for Seed payments not paid between 2001 and 2011. The trial court granted summary judgment for the State on all claims. The Supreme Judicial Court affirmed, holding (1) the breach of contract and quantum meruit claims were not legally viable; and (2) Murphy Homes failed to allege facts to generate a trial worthy issue of fact on the reliance element of its equitable estoppel claim. View "John F. Murphy Homes, Inc. v. State" on Justia Law

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Plaintiff filed suit against CMMC, seeking indemnification for expenses he incurred in defense of an administrative proceeding initiated by the Board of Licensure in Medicine. The Superior Court denied CMMC's motion to dismiss. The court concluded that section 2511 of the Main Health Security Act, 24 M.R.S. 2511, does not render CMMC immune from plaintiff's contractual claim for reimbursement. In this case, viewing the complaint in the light most favorable to plaintiff, the allegations in the complaint are sufficient to overcome a Rule 12(b)(6) motion because they state the elements of a cause of action and facts that would entitle plaintiff to relief pursuant to some legal theory. Accordingly, the court affirmed the trial court's order. View "Lalonde v. Central Maine Medical Center" on Justia Law

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Barnie’s Bar & Grill, Inc. held an insurance policy by the United States Liability Insurance Company (USLIC) when Barnie’s was sued for negligence in connection with one man’s attack by a group of other patrons of the bar. USLIC declined to defend Barnie’s in the litigation, relying on the policy’s exclusions for assault and battery. Barnie’s sued USLIC in superior court seeking a declaratory judgment that USLIC had a duty to defend it and seeking damages for breach of contract. The superior court granted summary judgment for USLIC, concluding that USLIC had no contractual duty to defend Barnie’s. The Supreme Judicial Court affirmed, holding that USLIC was not obligated to defend Barnie’s in the underlying litigation because the allegations of the underlying complaint fell squarely within the policy’s exclusions for assault and battery. View "Barnie's Bar & Grill, Inc. v. United States Liability Insurance Company" on Justia Law

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Arundel Valley, LLC, the developer of a facility for a butter manufacturer, filed a complaint against Branch River Plastics, Inc., a manufacturer and distributor of insulated roofing panels, alleging, inter alia, defects in roofing panels that Branch River had manufactured and supplied to Arundel Valley for a construction project. A jury found in Arundel Valley’s favor on its claims that Branch River breached implied warranties by supplying defective roofing panels. Branch River filed a motion for a new trial, which the court denied. The Supreme Judicial Court reversed, holding that the trial court erred in declining to adjudicate whether Branch River had disclaimed implied warranties. Remanded. View "Arundel Valley, LLC v. Branch River Plastics, Inc." on Justia Law