Justia Transportation Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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Randall J. Weddle was involved in a major motor vehicle accident in Washington, Maine, which resulted in the death of two drivers. The accident involved five vehicles, one of which was engulfed in flames. Weddle, the driver of a large tractor trailer, was found to be the cause of the accident. Hospital tests revealed that Weddle had alcohol in his system and officers found a three-quarters-full whiskey bottle and a shot glass in his truck several days after the accident.Weddle was charged with two counts of manslaughter, two counts of aggravated criminal operating under the influence, one count of causing injury while operating under the influence, one count of aggravated driving to endanger, one count of driving to endanger, and eight counts of violating commercial motor carrier operator rules. The jury found Weddle guilty of all counts. The court conducted a sentencing analysis and set the basic sentence at twenty years, considering the nature and circumstances of the crime. The court set the maximum sentence at thirty years, weighing mitigating and aggravating factors. The final sentence was set at thirty years, with all but twenty-five years suspended, followed by four years of probation.Weddle appealed his sentence to the Maine Supreme Judicial Court. He argued that his sentence was unconstitutional because it was not proportioned to the offense and that it was excessively harsh. The court affirmed the sentence, concluding that the sentence was not greatly disproportionate to the offense and did not offend prevailing notions of decency. The court also found that the sentence was not excessively harsh, as the court had considered both aggravating and mitigating factors in setting the maximum sentence. View "State of Maine v. Weddle" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court interpreting Me. Rev. Stat. 29-A, 2413-A to permit a determination that Defendant had committed three civil violations and to authorize the trial court to impose consecutive license suspensions, holding that the trial court did not err.Defendant admitted to three counts of committing a motor vehicle violation resulting in death pursuant to section 2413-A(1). After a penalty hearing, the trial court imposed a $5,000 fine and a three-year license suspension for each of the counts, with the fines being cumulative and the suspensions to be imposed consecutively. The Supreme Judicial Court affirmed the penalties, holding (1) section 2413-A(1) authorizes separate violations for each death that occurs as a result of a driving violation and authorizes trial courts to impose consecutive license suspensions under their discretion; and (2) the trial court in this case did not abuse its discretion when it imposed the consecutive suspensions. View "State v. Santerre" on Justia Law

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The Supreme Judicial Court affirmed the decision of the superior court denying the motion to compel arbitration brought by Uber Technologies, Inc. and Rasier, LLC (collectively, Uber) in this action brought by Patricia Sarchi, a user of Uber's ride-sharing service, and the Maine Human Rights Commission, holding that the superior court did not err.Plaintiffs brought this action against Uber for violating the Maine Human Rights Act, Me. Rev. Stat. 5, 4592(8), 4633(2), after Sarchi, who was blind, was refused a ride because of her guide dog. Uber moved to compel Sarchi to arbitrate and to dismiss or stay the action pending arbitration. The motion court denied the motion to compel, concluding that Sarchi did not become bound by the terms and conditions of Uber's user agreement. The Supreme Judicial Court affirmed, holding that, under the facts and circumstances of this case, Sarchi was not bound by the terms. View "Sarchi v. Uber Technologies, Inc." on Justia Law

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The Business and Consumer Docket did not err by determining that the Sensible Transportation Policy Act (STPA), Me. Rev. Stat. 23, 73, afforded the plaintiffs, who sought declaratory and injunctive relief regarding the Department of Transportation’s plan to widen Main Street in Wiscasset, no private right of action.Plaintiffs, four entities that owned property in Wiscasset, claimed that the Department violated various constitutional, statutory, regulatory, and municipal provisions in planning and designing a downtown improvement project calling for the widening and alteration of Maine Street. The court entered a judgment on the pleadings in favor of the Department as to all counts. As to count one, the court concluded that the STPA affords no private right of action and that Plaintiffs were precluded from seeking relief on that basis. The Supreme Judicial Court affirmed, holding that the STPA provides for no implied private right of action to allow enforcement of its terms. View "Wawenock, LLC v. Department of Transportation" on Justia Law

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Darling’s Auto Mall is a franchisee of General Motors LLC (GM) and and authorized dealer. Darling’s filed two small claims actions in district court alleging that it had been underpaid by GM for certain warranty repairs in violation of the Business Practices Between Motor Vehicle Manufacturers, Distributors and Dealers Act (Dealers Act). The district court ruled in favor of Darling’s on both small claims. GM appealed and requested a jury trial de novo. The superior court granted GM’s request. After a jury trial, the superior court entered a judgment in favor of GM. The Supreme Judicial Court affirmed, holding (1) the superior court’s decision to grant a jury trial de novo was not an appealable determination; (2) the trial court did not err in denying Darling’s motion for judgment as a matter of law; and (3) the trial court properly rejected Darling’s proposed jury instructions. View "Darling's Auto Mall v. General Motors LLC" on Justia Law