Justia Contracts Opinion SummariesArticles Posted in Maine Supreme Judicial Court
H&B Realty, LLC v. JJ Cars, LLC
The Supreme Judicial Court affirmed the judgment of the Business and Consumer Docket in favor of JJ Cars, LLC and John Mokarzel on H&B Realty, LLC's complaint for breach of contract, holding that there was no error in the court's judgment.The lower court determined that H&B breached the lease in this case by unreasonably withholding consent to a proposed sublease. On appeal, H&B argued that the court erred in applying the affirmative defenses, as pleaded by JJ Cars and Mokarzel, of breach of contract and failure to mitigate damages. The Supreme Judicial Court affirmed, holding that there was competent record evidence to support the court's finding that H&B materially breached the lease by refusing to consent to sublet the property. View "H&B Realty, LLC v. JJ Cars, LLC" on Justia Law
Corinth Pellets, LLC v. Arch Specialty Insurance Co.
The Supreme Judicial Court vacated the judgment of the superior court dismissing for failure to state a claim Corinth Pellets, LLC's complaint alleging that a fire loss at Corinth's wood pellet mill was covered under a commercial property insurance policy issued by Arch, holding that the superior court erred in its interpretation of Maine's surplus lines insurance law, Me. Rev. Stat. 24-A, 2009-A.On appeal, Corinth argued that the fire loss was covered under the policy, despite having occurred after the policy term had expired, because Arch failed notify Corinth of its intention not to renew the policy as required by section 2009-A, and therefore, the policy was automatically renewed at the end of the term. The Supreme Judicial Court vacated the judgment, holding that section 2009-A(1) requires a surplus lines insurer to give written notice of its intent either to cancel a policy or not to renew a policy at least fourteen days before the effective date of cancellation or nonrenewal. View "Corinth Pellets, LLC v. Arch Specialty Insurance Co." on Justia Law
Bibeau v. Concord General Mutual Insurance Co.
The Supreme Judicial Court affirmed the summary judgment entered by the superior court in favor of Concord General Mutual Insurance Company on Arthur Bibeau's complaint for alleged breaches and violations of the homeowner's insurance policy issued to him by Concord, holding that the policy did not unambiguously exclude from coverage losses caused by earth movement.Bibeau insured his home through a policy issued to him by Concord. Bibeau submitted a notice of claim to Concord alleging that his home was damaged by a water line leak that pushed sand and other material under the foundation of his home. Concord denied the claim based on the policy's earth movement exclusion and its anti-concurrent-causation clause. Bibeau then brought this action. The superior court granted summary judgment for Concord on all counts. The Supreme Judicial Court affirmed, holding that the superior court did not err in determining that the policy was unambiguous and that Bibeau's losses were excluded from coverage pursuant to the earth movement exclusion. View "Bibeau v. Concord General Mutual Insurance Co." on Justia Law
Cianchette v. Cianchette
The Supreme Judicial Court affirmed the judgment of the superior court in favor of Tucker Cianchette and CBF Associates, LLC (collectively, Tucker) and against Peggy Cianchette, Eric Cianchette, PET, LLC and Cianchette Family, LLC (collectively, Peggy and Eric) on Tucker's claims against Peggy and Eric and on Peggy and Eric's counterclaim against Tucker, holding that the superior court did not err in clarifying that post-judgment interest began to run on March 15, 2018.In this second appeal before the Supreme Court, the parties sought resolution of two legal issues regarding post-judgment interest: (1) whether the trial court had jurisdiction to issue an order on post-judgment interest, and (2) on what date prejudgment interest ceased and post-judgment interest began to accrue. The Supreme Judicial Court held (1) the trial court had authority to act and did not abuse its discretion in clarifying its judgments to resolve the parties' uncertainty surrounding post-judgment interest; and (2) post-judgment interest did not begin to run until the court entered the final judgment on March 15, 2018. View "Cianchette v. Cianchette" on Justia Law
TPR, Inc. v. Paychex, Inc.
The Supreme Judicial Court vacated the order entered by the superior court denying Defendant's motion to compel arbitration of, and dismissing all counts in, a complaint filed against it by Plaintiff, holding that the superior court did not make the statutorily required determination as to whether the parties agreed to arbitrate the dispute.In 2017, the parties entered into a contract whereby Defendant would provide payroll services to Plaintiff. In 2019, Plaintiff filed a complaint against Defendant asserting claims for fraud, negligence, and breach of contract. Defendant moved to dismiss the complaint and to compel arbitration under an arbitration clause contained in the parties' contract. The court denied Defendant's motion, holding that it could not be concluded as a matter of law that the parties entered into a valid agreement to arbitrate. The Supreme Judicial Court vacated the judgment, holding that remand was required because the trial court denied Defendant's motion without making the finding regarding arbitrability required by Me. Rev. Stat. 14, 5928(1). View "TPR, Inc. v. Paychex, Inc." on Justia Law
20 Thames Street LLC v. Ocean State Job Lot of Maine 2017, LLC
In this commercial forcible entry and detainer action brought by 20 Thames Street LLC and 122 PTIP LLC (collectively, 20 Thames) the Supreme Judicial Court affirmed the judgment of the superior court concluding that the district court lacked subject matter jurisdiction to award lease-based attorney fees upon finding for Ocean State Job Lot of Maine 2017, LLC, holding that the superior court did not err.Ocean State rented a commercial retail space from 20 Thames. 20 Thames later filed its compliant for forcible entry and detainer, alleging that Ocean State breached the terms of its lease. The business and consumer docket found in favor of Ocean State. The court awarded Ocean State costs and $206,076 in attorney fees based on a provision in the lease. The superior route affirmed the judgment for Ocean State but vacated the attorney fee award, concluding that the district court lacked jurisdiction to award lease-based attorney fees. The Supreme Judicial Court affirmed, holding that Me. Rev. Stat. 14, 6017 did not provide authority for the district court to award lease-based attorney fees. View "20 Thames Street LLC v. Ocean State Job Lot of Maine 2017, LLC" on Justia Law
Brown v. Compass Harbor Village Condominium Ass’n
The Supreme Judicial Court vacated in part and affirmed in part the lower court's judgment in favor of Plaintiffs and against Compass Harbor Village Condominium Association and Compass Harbor Village, LLC (collectively, Compass Harbor), holding that the court erred in ordering specific performance and entering judgment for Plaintiffs on the claim brought pursuant to the Maine Unfair Trade Practices Act (UTPA), Me. Rev. Stat. 5, 205-A to 2014.Plaintiffs brought suit alleging that Compass Harbor's actions with respect to maintenance and governance of the Association caused their units to lose value. The lower court found that Compass Harbor breached the contracts between it and Plaintiffs, the LLC violated its fiduciary duties to Plaintiffs, and Compass Harbor violated section 207 of the UTPA. The court awarded damages to Plaintiffs and entered an order of specific performance requiring Compass Harbor to abide by its contractual and fiduciary duties in the future. The Supreme Judicial Court vacated the judgment in part, holding (1) the UTPA did not apply in this case; (2) the court did not clearly err in calculating damages; and (3) the court went beyond its discretion in entering an order that would involve the court in continuous supervision of Compass Harbor's performance over an indefinite period. View "Brown v. Compass Harbor Village Condominium Ass'n" on Justia Law
InfoBridge, LLC v. Chimani, Inc.
In this dispute over a purported royalty fee, the Supreme Judicial Court vacated the superior court's order granting partial summary judgment in favor of InfoBridge, LLC on InfoBridge's claim for breach of contract, holding that the contract's royalty provision was ambiguous.Chimani and InfoBridge entered into a contract under which InfoBridge would create a software program. For this work, Chimani was to pay InfoBridge scheduled payments. The contract also contained a royalty provision requiring Chimani to pay InfoBridge royalties. InfoBridge later filed a complaint against Chimani alleging, inter alia breach of contract. InfoBridge then moved for partial summary judgment on its breach of contract claim, arguing that the royalty provision unambiguously required Chimani to pay InfoBridge 14.5 percent of Chimani's net revenue from the program, up to a total royalty fee of $150,000. The court granted the motion for summary judgment and denied Chimani's cross-motion for summary judgment on its equitable estoppel affirmative defense on the grounds that Chimani waived the equitable estoppel issue. The Supreme Court affirmed in part and vacated in part the judgment below, holding (1) Chimani waived its equitable estoppel defense; but (2) the royalty provision was ambiguous, and the summary judgment record did not permit a determination of its meaning as a matter of law. View "InfoBridge, LLC v. Chimani, Inc." on Justia Law
Wuestenberg v. Rancourt
The Supreme Judicial Court affirmed the decision of the superior court in favor of Defendants following a bench trial on Plaintiffs' claims against Defendants stemming from Plaintiffs' purchase of Defendants' house, holding that the trial court's factual findings were supported by the evidence and that the court did not err in deciding in favor Defendants.Defendants entered into a purchase and sale agreement with Plaintiffs to sell Defendants' home. After Plaintiffs discovered a number of deficiencies in the house they filed a complaint alleging counts arising from the house's sale and defects. The trial court granted judgment in favor of Defendants. The Supreme Judicial Court affirmed, holding that the trial court's explicit findings were comprehensive, detailed, and adequately supported by record evidence. View "Wuestenberg v. Rancourt" on Justia Law
Fortney & Weygandt, Inc. v. Lewiston DMEP IX, LLC
In this appeal arising from a set of commercial construction projects the Supreme Judicial Court affirmed the judgment in favor of Fortney & Weygant, Inc. (F&W) on the counterclaims filed by Lewiston DMEP IX, LLC, et al. (collectively, GBT) for liquidated damages, affirmed in part as to the prompt payment remedies allowed to F&W, and vacated the portion of the judgment awarding attorney fees and costs to F&W pursuant to the terms of the parties' contract.The trial court determined that, in addition to damages for breach of contract, F&W was entitled to remedies, including attorney fees pursuant to Maine's prompt payment statutes, that F&W was entitled to attorney fees pursuant to the terms of the parties' contract, and that GBT was estopped from seeking to enforce a contractual right to liquidated damages against F&W. The Supreme Judicial Court held that the trial court (1) did not erroneously conclude that GBT was equitably estopped from recovering liquidated damages against F&W; (2) properly awarded F&W prompt payment remedies except to the extent that the remedy failed to account for the value of GBT's liquidated damages claims that GBT withheld in good faith; and (3) erred when it concluded that the contract contemplated an award of attorney fees outside the context of arbitration. View "Fortney & Weygandt, Inc. v. Lewiston DMEP IX, LLC" on Justia Law