Justia Government & Administrative Law Opinion Summaries

After Robert Rossignol was notified that his teaching contract would not be renewed, Rossignol applied to the Maine Public Employees Retirement System (MPERS) for disability retirement benefits. Rossignol alleged that he suffered from depression, anxiety, and panic attacks, which made it impossible for him to perform the duties of his position. The Executive Director’s designee denied Rossignol’s application. The MPERS Board of Trustees affirmed the denial of disability retirement benefits. The Supreme Court affirmed, holding that Rossignol failed to demonstrate that, under the governing statutory standard, he was entitled to disability retirement benefits. View "Rossignol v. Maine Pub. Employees Ret. Sys." on Justia Law

In 2015, the Department of Health and Human Services filed a petition to terminate Father’s parental rights to his son. At the commencement of the termination hearing, Father told the court that he was unwell and that he wanted to reschedule the hearing. The court allowed Father to leave and told him the hearing would be rescheduled if Father filed a doctor’s note. Father never filed a doctor’s note and no rehearing was scheduled. The court subsequently terminated Father’s parental rights. The Supreme Judicial Court affirmed, holding that the court did not violate Father’s right to due process when it conducted the termination hearing in Father’s absence. View "In re Adden B." on Justia Law

Plaintiff applied to the State Harness Racing Commission to renew his driver/trainer license for horse harness racing in Maine. The Commission denied the application because Plaintiff had previously been denied a license by a racing authority in New York. The Commission based its conclusion that the reciprocal disciplinary action provision of the harness racing licensing statute prohibited the issuance of the Maine license even though New York had subsequently rescinded its license denial. The Supreme Judicial Court vacated the judgment and remanded for further proceedings, holding that the Commission erred in its interpretation of the statute. View "Mosher v. State Harness Racing Comm’n" on Justia Law

After taking maternity leave, Plaintiff returned to work. She quit, however, after disputes between her and Employer arose over a change to her schedule that made her childcare situation more difficult, and over an appropriate place for her to pump breast milk at work. The Bureau of Unemployment Compensation denied Plaintiff’s claim for unemployment benefits. The Department of Labor’s Division of Administrative Hearings affirmed. The Unemployment Insurance Commission affirmed, concluding that Plaintiff “was not able and available for full-time work” within the meaning of Me. Rev. Stat. 26, 1192(3). The superior court affirmed. The Supreme Judicial Court affirmed, holding that the Commission did not err in its construction of the statute and that its decision was not contrary to public policy. View "Cheney v. Unemployment Ins. Comm’n" on Justia Law

Plaintiff filed an application for disability retirement benefits alleging that she was unable to perform her job with the Maine Department of Transportation because of her numerous disabilities. The Maine Public Employees Retirement System Board of Trustees denied benefits after considering Plaintiff’s medical records. Plaintiff appealed, challenging only the denial of benefits as to her fibromyalgia. The Supreme Judicial Court affirmed, holding (1) the medical board’s reports were a proper part of the evidentiary record; and (2) the record did not compel a finding that Plaintiff met her burden of proving that her fibromyalgia caused functional limitations that made it impossible for her to do her job. View "Behr v. Maine Pub. Employees Ret. Sys." on Justia Law

Fryeburg Water Company (FWC) sought approval from the Public Utilities Commission to execute an agreement with Nestle Waters North America, Inc. (NWNA) providing for the lease of premises and purchase of water from FWC. After an adjudicatory proceeding concerning the request, the Commission conditionally approved the proposed agreement. Bruce Taylor and Food & Water Watch appealed, challenging the Commission’s procedural decisions and the Commission’s ultimate approval of the agreement. The Supreme Court affirmed, holding that there was no abuse of discretion or violation of a statutory or constitutional provision in the Commission’s decision approving FWC’s proposed agreement with NWNA. View "Taylor v. Pub. Utils. Comm’n" on Justia Law

Mainers for Fair Bear Hunting (MFBH) is a Maine ballot question committee that was a proponent of November 2014 Ballot Question 1 concerning bear hunting and trapping. As early as September 2013, the Department of Inland Fisheries and Wildlife used agency resources to communicate with the public in opposition to Question 1. MFBH filed a complaint against the Department alleging that the Department’s campaign activities constituted an ultra vires expenditure of public funds. In November 2014, Maine voters defeated the ballot question. The Department subsequently filed a motion to dismiss MFBH’s complaint on the grounds of mootness and standing. In March 2015, the superior court dismissed the complaint as moot. The Supreme Court affirmed, holding that the case is moot and that no exceptions to the mootness doctrine apply. View "Mainers for Fair Bear Hunting v. Dep’t of Inland Fisheries & Wildlife" on Justia Law

Brenda Freeman was injured in a work-related accident in 2007. Freeman returned to work but in a lower-paying position. Because of the decrease in her wages, Freeman received partial incapacity benefit payments. In 2011, Freeman suffered a second work-related injury. During Freeman’s period of incapacity, her employer paid 100 percent partial incapacity benefits based on the 2007 injury. Freeman filed a petition for award of compensation claiming that although she was already receiving benefits that equaled the maximum compensation rate as a result of her 2007 injury, she was eligible for additional compensation for the same period as a result of her 2011 injury. The hearing officer concluded that Freeman was ineligible for compensation beyond the statutory maximum benefit, regardless of the number of injuries. The Workers’ Compensation Board Appellate Division affirmed. The Supreme Judicial Court affirmed, holding that the hearing officer correctly construed the statutory maximum benefit provision of the Workers Compensation Act as a total ceiling on the potential benefits available to an injured employee, regardless of the number of injuries the employee suffers. View "Freeman v. NewPage Corp." on Justia Law

Somerset County receives income generated by boarding federal prisons at the Somerset County Jail (SCJ). That income is used to support the jail budget. During fiscal year 2013, the County received more federal boarding revenue than anticipated. Without consulting with or receiving approval from the former State of Maine Board of Corrections, the County applied a portion of that surplus income to debt service for the cost to construct the SCJ facility. In response, the Board correspondingly reduced the amount of the County’s corrections funding from other sources. The County appealed. The superior court vacated the Board’s decision to withhold funding, concluding that pertinent legislation did not authorize the Board to adjust payments to the County as a result of the County’s unauthorized use of surplus federal boarding income. The Supreme Judicial Court vacated the superior court’s judgment and remanded for entry of judgment in favor of the Department of Corrections, as the party substituted for the Board, holding that the Board acted within its authority when it took action affecting the funding otherwise due to the County. View "Somerset County v. Dep’t of Corr." on Justia Law

In this case, the Supreme Court considered when a municipal agency’s decision constitutes a final action subject to immediate judicial review. The owner of the Camden Harbour Inn applied to the Town of Camden for authorization to increase the number of guest rooms and parking spaces for the Inn and to reduce the number of seats at the Inn’s restaurant. The Zoning Board of Appeals (ZBA) granted a special exception permit subject to conditions and allowed the Inn to proceed to the Planning Board for site plan review. Susan Bryant, an abutter, appealed the ZBA’s decision to the superior court before site plan review could occur. The superior court affirmed the ZBA’s decision. The Supreme Court vacated the judgment of the superior court and remanded for dismissal of Bryant’s complaint, holding that, while the Town’s Zoning Ordinance expressly provided for Bryant’s appeal from the grant of the preliminary special permit, the ZBA’s decision was not a final action subject to appellate review in the courts because additional process was required by the Town’s Ordinance before a final decision on the Inn’s proposed changes is reached. View "Bryant v. Town of Camden" on Justia Law