Cummings v. Bean, 2004 ME 93

Summary

The Maine Supreme Judicial Court affirmed the denial of David Bean’s motion for relief from a judgment under Maine Rule of Civil Procedure 60(b)(4). The court held that quantum meruit is a legal claim for monetary damages rather than an equitable claim, and therefore the District Court had subject matter jurisdiction under 4 M.R.S.A. § 152(2).

Holdings

1. The District Court had subject matter jurisdiction because quantum meruit is a legal claim for monetary damages, not an equitable claim, and 4 M.R.S.A. § 152(2) grants the District Court original concurrent jurisdiction over civil actions seeking money damages when no equitable relief is demanded.
2. Relief under Rule 60(b)(4) was not warranted because the judgment was not void; the District Court had subject matter jurisdiction over the quantum meruit claim.

Questions Presented

1. Whether the District Court had subject matter jurisdiction over Cummings's quantum meruit claim for money damages.
2. Whether the judgment was void and therefore subject to relief under M.R. Civ. P. 60(b)(4).

Disposition

affirmed