Justia Business Law Opinion Summaries

In this case, Randall C. Belyea was the sole shareholder and president of Belyea Enterprises, Inc. (BEI), which had a contract with FedEx. Due to a misdemeanor charge, FedEx refused to renew the contract with Belyea, leading him to transfer his interest in BEI to his fiancée, Heather A. Campbell, under the understanding that she would be the owner in name only while he continued to run the business. However, in 2018, Campbell terminated Belyea's employment and restricted his access to BEI's bank accounts.The Superior Court (Aroostook County) initially granted Campbell’s motion for judgment as a matter of law on Belyea’s conversion claim and later entered judgment as a matter of law in favor of Campbell on Belyea’s breach of contract claim, despite a jury verdict in Belyea’s favor. The court found that there was insufficient evidence of an enforceable contract between Belyea and Campbell, as the terms were too vague and indefinite.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's decisions. The court held that the terms of the alleged contract between Belyea and Campbell were not sufficiently definite to form an enforceable contract. The terms did not clearly define the roles and obligations of each party, the duration of the contract, or the details regarding a possible reconveyance of BEI to Belyea. Consequently, the court also upheld the judgment in favor of Campbell on the conversion claim, as Belyea did not have a legal interest in BEI in 2018. View "Belyea v. Campbell" on Justia Law

The case revolves around a dispute between MMG Insurance Company (MMG) and the Estate of Philip J. Greenlaw. The dispute arose after the death of Philip Greenlaw, who died while wrestling with his friend, Joseph McNeely. Prior to the incident, McNeely, who operated a landscaping business, had visited Greenlaw's house to provide an estimate for a landscaping project. The visit was part of an informal social gathering where business-related topics were often discussed. After the incident, the Estate filed a wrongful death action against McNeely. MMG, which had issued a business insurance policy to McNeely, sought a declaratory judgment that it had no duty to indemnify McNeely in the wrongful death action.The Superior Court (Cumberland County) granted MMG's motion for summary judgment, determining that McNeely was not covered as an insured under MMG’s business insurance policy because his actions while wrestling with Greenlaw were not related to the conduct of his landscaping business. The Estate appealed this decision, arguing that there were triable issues of fact regarding whether Greenlaw’s death occurred with respect to the conduct of McNeely’s business.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court found that the insurance policy provision was unambiguous and that McNeely was covered as an insured only with respect to the conduct of his business. The court also agreed with the lower court's determination that there was no genuine issue of material fact and that McNeely’s actions while wrestling with Greenlaw were not related to the conduct of his landscaping business. Despite the business-related discussions and activities that occurred earlier in the evening, the court concluded that McNeely's wrestling actions were not taken with respect to the conduct of his business. View "MMG Insurance Company v. Estate of Greenlaw" on Justia Law

The Supreme Judicial Court dismissing Appellant's appeal from an order entered by the business and consumer docket dismissing two of three counts in Appellant's action against Flats Industrial, Inc. and three other Flats shareholders (collectively, Appellees), holding that Appellant's notice of appeal was untimely filed.Appellant, a Flats shareholder, filed this action claiming that Flats improperly failed to disclose records and breach of fiduciary duty. The court dismissed counts two and three of the second complaint and left count one as the only remaining claim for relief in the action. The parties later stipulated to the dismissal of count one. Appellant appealed, and Appellees moved to dismiss the appeal on the ground that Appellant's notice of appeal was not timely filed under Me. R. App. P. 2B(c)(1). The Supreme Judicial Court dismissed the appeal for lack of jurisdiction, holding that Appellant's appeal was filed after the deadline for appeal had expired. View "Fournier v. Flats Industrial, Inc." on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing Appellant's complaint for lack of personal jurisdiction over Defendant, holding that Maine had personal jurisdiction over Defendant in this case.Plaintiff was a Delaware limited liability company with its principal place of business in Maine. Defendant was a Delaware corporation with its principal place of business in California. Plaintiff brought this action asserting a claim of tortious interference with contractual and advantageous economic relations against Defendant. The district court dismissed the complaint on the ground that Maine lacked jurisdiction over Defendant. The Supreme Judicial Court vacated the judgment below, holding that all of the due process requirements were met, and therefore, the trial court had specific personal jurisdiction over Defendant. View "Premier Diagnostics v. Invitae Corp." on Justia Law

In this business dispute involving several tort claims the Supreme Judicial Court affirmed the judgment of the business and consumer docket dismissing the complaint for failure to state a claim, holding that the trial court did not err in dismissing the complaint.Plaintiff sued three Delaware corporations asserting aiding and abetting breaches of fiduciary duty, tortious interference, and conspiracy. The trial court dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Judicial Court affirmed, holding that all of Plaintiffs claims against Defendants failed. View "Meridian Medical Systems, LLC v. Epix Therapeutics, Inc." on Justia Law

The Supreme Judicial Court affirmed the business and consumer docket's entry of final judgment reaffirming a partial summary judgment on the complaint filed by Michael Zelman and a counterclaim filed by Andrew and Zelman Family Business Holdings, LLC (ZFBH), holding that the business and consumer court had subject matter jurisdiction.Michael brought this action both individually and as personal representative of the Estate of Estelle Betty Zelman asking the superior court to dissolve and liquidate ZFBH. Andrew and ZFBH filed an answer and counterclaim. The court entered a final judgment concluding that Andrew was not a manager of ZFBH and that the sole remaining manager of ZFBH had died and declining to dissolve ZFBH. The Supreme Judicial Court affirmed, holding (1) the business and consumer court had subject matter jurisdiction and personal jurisdiction; and (2) the court correctly concluded that William did not have the authority to appoint Andrew as a manager of ZFBH. View "Zelman v. Zelman" on Justia Law

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

The Supreme Judicial Court affirmed the portion of the superior court’s order denying Defendant’s special motion to dismiss a multipoint complaint against him pursuant to Maine’s anti-SLAPP statute, holding that the complaint was not based on Defendant’s petitioning activities within the meaning of the anti-SLAPP statute, and therefore, the court did not err by denying Appellant’s special motion to dismiss.Plaintiffs filed a complaint against Defendant alleging defamation, false light, tortious interference with advantageous business relationships, and intentional infliction of emotional distress (IIED). Defendant filed a motion to dismiss pursuant to the anti-SLAPP statute, Me. Rev. Stat. 14, 556. The superior court denied the motion but granted in part Defendant’s motion for partial judgment by dismissing the IIED claim. The Supreme Judicial Court addressed only the denial of Defendant’s special motion to dismiss and affirmed, holding that the superior court correctly determined that a substantial majority of Defendant’s statements and conduct were not petitioning activities within the meaning of the anti-SLAPP statute. View "Hearts with Haiti, Inc. v. Kendrick" on Justia Law

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

This dispute arose out of the franchise relationship between Ford Motor Company and Darling’s, an automobile dealer. In Ford I, the Maine Motor Vehicle Franchise Board entered an award of damages against Ford, concluding that Ford violated the Business Practices Between Motor Vehicle Manufacturers, Distributors, and Dealers Act (Dealers Act) by failing to provide Darling’s with proper notice of a franchise modification. The Business and Consumer Docket (BCD) affirmed the Board’s damages award. The Supreme Court affirmed most aspects of the judgment but held that the Board lacked jurisdiction to award damages for violations of the Dealers Act. On remand, after a jury trial, the BCD awarded Darling’s damages of $154,695 based on Ford’s violation of the statutory notice provision. The Supreme Court affirmed the judgment in part and vacated it part, holding (1) the court did not err by reducing Darling’s damages by the amounts it received under an incentive program; but (2) the court erred as a matter of law by limiting Darling’s recovery to a 270-day period. Remanded to the BCD for a new trial on the issue of damages. On remand, Ford is entitled to an offset of any damages awarded to Darling’s based on payments that Darling’s received pursuant to the incentive program. View "Ford Motor Co. v. Darling's" on Justia Law