John A. Woodcock jr

In this bankruptcy appeal, secured creditors Beacon Investments LLC and United Express Wireless, Inc. challenged the Bankruptcy Court's approval of MainePCS LLC's settlement of pending litigation against competitor Northeast Wireless Networks, LLC. The District Court affirmed the approval, concluding that the Bankruptcy Court did not abuse its discretion in approving the compromise, that the appellants had waived their argument that the 'entire fairness' standard should apply to the settlement, and that even if that standard had been applied the result would have been the same. The Court also held that under MainePCS's operating agreement, the vote of two of the three managers was sufficient to authorize the settlement. The underlying dispute arose from MainePCS's failed contracts with T-Mobile and subsequent dealings involving its board members and lenders.

business & regulatoryprocedure

In United States v. Corbin, defendant Paul Corbin faced federal charges for possession with intent to distribute marijuana and methamphetamine, plus unlawful firearm possession, and moved to disqualify the presiding judge under 28 U.S.C. §§ 144 and 455. The motion cited the judge's published statements to a newspaper about the risks of methamphetamine trafficking from Canada into Maine, along with a DOJ report on border security distributed to judges. The court denied the motion, ruling that the statements reflected general judicial observations on public safety issues rather than personal bias or prejudice against the defendant. It held that neither the comments nor the report created an objective basis for questioning the judge's impartiality, as recusal requires a factual showing that a reasonable person would doubt neutrality, and the affidavit was legally insufficient.

criminal lawprocedure

This case involves pro se plaintiff Randall Hofland's civil lawsuit against Richard LaHaye and others, stemming from events leading to Hofland's 2008 arrest; Hofland repeatedly attempted to amend his complaint over two years while the case was stayed for related criminal proceedings. The magistrate judge screened the fourth proposed amended complaint under 28 U.S.C. § 1915, found no viable claims, and recommended dismissal along with filing restrictions. The district court affirmed the recommended decision, struck the latest filings, entered judgment for defendants, and imposed pre-filing injunctions after determining that Hofland had filed multiple meritless suits, refused to accept prior rulings, and engaged in dilatory and abusive litigation tactics. The core reasoning was that federal courts should not expend resources on frivolous matters and that Hofland's pattern of conduct justified restrictions under Cok v. Family Court of Rhode Island.

procedure

In United States v. Farlow, the defendant, after entering a conditional guilty plea to charges of transporting and possessing child pornography under 18 U.S.C. § 2252A, was sentenced to 120 months in prison and appealed an order denying his motion to suppress evidence from a computer search. Farlow then moved for release pending appeal under 18 U.S.C. § 3145(c), arguing he posed no flight risk or danger to the community, raised substantial questions about the search's legality, and had exceptional reasons for release due to his serious illness. The government opposed, citing his criminal history involving sexual offenses against minors and arguing no substantial appellate issues or exceptional circumstances existed. The court denied the motion, concluding Farlow failed to demonstrate by clear and convincing evidence that his appeal raised a substantial question likely to result in reversal and that no exceptional reasons justified release despite his health issues. The decision applied standards from § 3143(b) and considered factors such as the nature of the offense and prior conduct.

criminal lawprocedure

The United States sued two Southwest Harbor residents under the False Claims Act, alleging they submitted invoices and received federal grant funds for installing a town surveillance camera system that was actually installed by volunteers without compensation. The defendants moved for summary judgment, contending there was no evidence of false claims or unjust enrichment. The court denied the motion, concluding that genuine disputes of material fact existed about whether the billed installation services were performed and whether the government relied on inaccurate invoices when disbursing the grant money. This evidence was sufficient to allow the FCA claims, as well as common-law claims for unjust enrichment, payment by mistake, and accounting, to proceed to trial.

criminal lawfederal power

In United States v. Sanchez-Ramirez, the defendant filed motions under Federal Rule of Civil Procedure 60(b) to reopen the court's prior denial of his 28 U.S.C. § 2255 petition to vacate his sentence and for appointment of counsel. The § 2255 petition had raised claims including the lack of a competency hearing, ineffective assistance of counsel regarding sentencing factors and jury trial waiver, and improper use of prior burglary convictions as predicates for Armed Career Criminal Act (ACCA) sentencing enhancement under 18 U.S.C. § 924(e). The court denied the motions, holding that the defendant could not reopen an appeal he had voluntarily dismissed, that the cited intervening case Johnson v. United States was neither new nor applicable to his burglary predicates, that the ineffective assistance claim regarding jury waiver had already been rejected, and that the ACCA enhancement properly applied to his prior convictions rather than his current firearm possession offense.

criminal lawproceduregunsfederal power

In 2008, a Maine resident contacted a Florida-based spinal surgery provider, underwent two procedures there after assurances about insurance coverage, and later sued the institute and surgeon in Maine state court on nine counts including fraud, breach of contract, negligence, and emotional distress claims. The defendants moved to dismiss for lack of personal jurisdiction, improper venue, and failure to comply with Florida medical malpractice statutes or the Maine Health Security Act's pre-litigation notice and screening rules. The court held that the defendants' contacts with Maine (including phone calls, faxes, and payment arrangements) established personal jurisdiction and that venue was proper in the District of Maine, while concluding Florida's statute of limitations did not bar the action. However, because the Maine Health Security Act applied to the malpractice-related claims, the court dismissed without prejudice the portion of the motion based on noncompliance with that Act and stayed the case to permit the plaintiff to complete the required pre-litigation procedures.

healthcareproceduretorts & liability

The case involved securities traders and their firms seeking a federal court temporary restraining order to halt an upcoming disciplinary hearing by the Maine Office of Securities that could suspend or revoke a trader's license, based on claims that the state administrator was biased and should be disqualified. The district court denied the TRO. It applied the Younger abstention doctrine, finding an ongoing state quasi-judicial proceeding that implicated important state interests in securities regulation, with an adequate opportunity for the plaintiffs to raise their constitutional claims in state court. The court concluded that no extraordinary circumstances, such as proven structural or actual bias, justified federal intervention despite parallel state court denials of similar relief.

business & regulatoryprocedurefederal power

In this case, plaintiff John Thomas Berry sued defendant Worldwide Language Resources, Inc. on multiple claims arising from their business relationship, including promissory estoppel, fraud, negligent misrepresentation, and others; a jury awarded Berry $25,000 on the promissory estoppel claim while Worldwide prevailed on the remaining counts. Both parties then sought costs under Federal Rule of Civil Procedure 54(d) as the prevailing party. The court held that Berry was the prevailing party and thus entitled to costs, reasoning that the central issue in the litigation was whether Worldwide owed Berry any money damages at all, and Berry obtained a monetary recovery on that issue despite losing on the other counts.

procedure

The case involved John Thomas Berry's lawsuit against his former employer, Worldwide Language Resources, Inc., for improper termination under various theories including promissory estoppel, which a jury resolved in Berry's favor with a $25,000 award. Worldwide renewed its motion for sanctions, alleging that Berry committed perjury by misrepresenting his marital status with Marianna Chachkova on his employment application and engaged in witness tampering by contacting her current husband after his deposition to align their accounts. The court denied the motion, concluding that Worldwide failed to prove perjury or tampering. The core reasoning was that the jury had already evaluated and rejected the fraud allegations underlying the perjury claim, and the court independently found insufficient evidence to support the witness tampering accusation given conflicting witness accounts and lack of corroboration.

procedurelabor & employment

The case involved defendant Kevin Earl Spring, who was indicted on charges of making false statements in connection with acquiring a firearm under 18 U.S.C. § 922(a)(6) and § 924(a)(1)(A), as well as possessing a firearm after commitment to a mental institution under § 922(g)(4), following an emergency psychiatric admission in Maine. Spring moved to dismiss the indictment, arguing that the emergency admission process violated due process for purposes of the gun prohibition, that the government violated the Speedy Trial Act's timing requirements, and that the two false-statement counts were multiplicitous. The court denied all motions to dismiss. It held that the due process claim could not be resolved pretrial because it turned on factual issues for the jury, that the timeline between arrest and indictment complied with the Speedy Trial Act, and that the two false-statement charges were not multiplicitous under the Blockburger test because each statute requires proof of an element the other does not.

gunscriminal lawprocedurecivil rights

In United States v. Stone, the dispute centered on Adam Stone's § 2255 petition alleging ineffective assistance by his former counsel during sentencing for a child pornography conviction. The government sought an order compelling the attorney to release client files and submit to an informal interview to defend against the claim. Magistrate Judge Kravchuk granted limited discovery, ordering document production and a deposition attended by both parties' counsel. The district court denied the government's motion to reconsider, finding no manifest error of law or fact in the magistrate's application of Rule 6 of the Rules Governing Section 2255 Cases and related privilege principles.

criminal lawprocedure

William Quirion pleaded guilty to federal charges of possessing marijuana with intent to distribute and being a felon in possession of a firearm. After his release on conditions including no new law violations and no drug use, the government moved to revoke release following his arrest for state theft and evidence of ongoing opiate and marijuana use. The court conducted a detention hearing under 18 U.S.C. § 3148 and found probable cause that Quirion committed a state crime while on release, clear and convincing evidence of a drug-abstinence violation, and that no release conditions would assure compliance or community safety based on factors in § 3142(g). The court therefore revoked the release order and ordered detention pending sentencing.

criminal lawprocedure

The case involved Rodney Russell, who was convicted by a jury of four counts of making false statements regarding his income and employment to obtain subsidized health insurance through Maine's DirigoChoice program, in violation of 18 U.S.C. § 1035(a)(2). The court denied his motion for judgment of acquittal, finding sufficient evidence supported the jury's verdict that the statements were materially false. It also denied his motion for a new trial, ruling there were no procedural errors and that inconsistent jury verdicts do not provide grounds for retrial.

criminal lawhealthcare

In Knowlton v. Shaw, a former branch sales manager sued his employer Bankers Life, several of its executives, and state of Maine officials after his removal from the position, asserting claims under 42 U.S.C. § 1983 for deprivation of a property interest without due process, slander, negligent and fraudulent misrepresentation, breach of contract, breach of the implied covenant of good faith and fair dealing, promissory estoppel, and seeking punitive damages. The defendants moved for summary judgment. The court granted the motion in part, dismissing the § 1983 claims because the plaintiff was an at-will employee under the employment contract and thus lacked a protected property interest in continued employment, dismissing the slander claims for lack of evidence linking the defendants to the statements, and dismissing the contract-based claims because the contract expressly provided for at-will employment and company policies did not alter that status. The court denied the motion as to the negligent and fraudulent misrepresentation claims to the extent they sought economic losses and as to punitive damages.

labor & employmentcivil rightstorts & liability

In Morin v. Eastern Maine Medical Center, the plaintiff, after winning a jury verdict for compensatory and punitive damages in an EMTALA claim against the defendant hospital, moved to amend the judgment to add prejudgment interest under Maine law. The court granted prejudgment interest on the $50,000 compensatory damages award but denied it on the $150,000 punitive damages award. The decision rested on the principle that Maine's prejudgment interest statute compensates for the inability to use funds during litigation and thus applies only to compensatory damages, while state precedent and policy preclude interest on punitive damages as it would not serve a compensatory function.

healthcareproceduretorts & liability

This case involves a dispute between OfficeMax and its former employees at County Qwik Print, where OfficeMax sued for breach of noncompetition agreements and violation of trade secrets laws, and the employees countersued for breach of a compensation contract, fraud in profit calculations affecting bonuses, and untimely wage payments under Maine statute. The court addressed OfficeMax's motion to dismiss three counterclaims and the employees' motion to amend them. It dismissed the fraud counterclaim without prejudice for failing to meet heightened pleading specificity requirements but denied dismissal of the breach of contract and wage statute claims, finding they sufficiently stated grounds for relief. The court granted the motion to amend the surviving counterclaims while denying it for the fraud claim.

business & regulatorylabor & employmentprocedure

In United States v. Goodrich, the defendant was charged with unlawful possession of a firearm after having been involuntarily committed to a mental institution, and he moved to dismiss the indictment on grounds of entrapment by estoppel, supported by a stipulation of facts showing he received a letter from a hospital doctor clearing him to possess firearms and that state authorities did not report his commitment to the background check system. The court denied the motion to reconsider its earlier ruling rejecting dismissal. The core reasoning was that a motion to dismiss an indictment is not a proper vehicle to resolve fact-intensive defenses like entrapment by estoppel, which require evaluation of evidence and witness credibility at trial by a jury rather than pretrial adjudication based on stipulated facts outside the indictment's allegations.

criminal lawgunsprocedure

In United States v. Farlow, the defendant was indicted on federal child pornography charges and entered a conditional guilty plea to one count after the court denied his motion to suppress evidence obtained from a search of his computer. Farlow later moved to withdraw his plea and reconsider the suppression ruling, arguing that a new First Circuit decision required an evidentiary hearing on the search. The court evaluated the five factors governing withdrawal of guilty pleas and concluded that the new precedent did not mandate a hearing because the facts were undisputed and Farlow had not presented a substantial claim beyond hoping to undermine the government's expert on cross-examination. The court therefore denied the motion to withdraw the plea.

criminal lawprocedure

In this case, the defendant was convicted by a jury of being a felon in possession of a firearm and ammunition. The Government moved for a court-ordered presentence psychiatric or psychological examination under 18 U.S.C. § 3552(c) prior to completion of the Presentence Investigation Report (PSR), citing the defendant's conduct and statements before, during, and after the offense. The defendant objected that the request was premature and that any evaluation should occur only after the PSR was reviewed. The court denied the motion without prejudice, concluding that while the statute permits an examination before or after the PSR, it was preferable to first obtain the PSR, assess whether additional information was needed, and allow the defendant an opportunity to cooperate voluntarily to ensure the validity of any report. The court indicated it would revisit the issue after the PSR was completed.

criminal lawprocedure