Daniel R. Lalonde v. Central Maine Medical Center

Summary

The Maine Supreme Judicial Court affirmed the denial of Central Maine Medical Center’s motion to dismiss Daniel R. Lalonde’s claim for indemnification of expenses incurred defending a medical licensing-board proceeding. The court held that immunity under 24 M.R.S. § 2511 for reports to a professional board did not bar Lalonde’s contractual indemnification claim under CMMC’s bylaws. The court concluded that the complaint adequately pleaded a claim for relief and that CMMC was not immune from the indemnification action.

Holdings

1. An interlocutory appeal is permitted from an order denying a motion to dismiss when the asserted basis for dismissal is the defendant's complete or qualified immunity from suit.
2. Section 2511 does not immunize CMMC from Lalonde's contractual action seeking indemnification for defense costs because the action seeks enforcement of a contractual indemnification obligation, not damages or other relief based on CMMC's report to the Board.
3. Lalonde's complaint stated a claim for contractual indemnification because it alleged a legally binding contract created by CMMC's bylaws, a material breach of the indemnification provision, and damages in the form of defense expenses.

Questions Presented

1. Whether the interlocutory appeal was permissible under the final judgment rule because CMMC asserted immunity under 24 M.R.S. § 2511.
2. Whether 24 M.R.S. § 2511 immunized CMMC from Lalonde's contractual claim for indemnification of attorney fees and costs incurred in defending the Board proceeding.
3. Whether Lalonde's complaint stated a claim for contractual indemnification under CMMC's bylaws.

Disposition

affirmed