Manon Cote et al. v. Roger Vallee et al.

Summary

The Maine Supreme Judicial Court affirmed a Superior Court judgment arising from a small claims dispute concerning an alleged breach of a license agreement to provide running water. The Court held that a party may not invite or consent to deviations from the procedural rules governing small claims appeals and later claim prejudice from those deviations. The Court also declined to impose appellate sanctions because the request was not made by separate motion and the appellees had participated in the procedural departures.

Holdings

1. A defendant appealing a small claims judgment to the Superior Court has only two procedural options: appellate review on questions of law based on the District Court record, or a jury trial de novo after demonstrating a genuine issue of material fact. There is no right to a second bench trial de novo.
2. A party may not invite or consent to deviations from the required appellate process and then obtain appellate relief based on those same deviations after the result proves unfavorable. The Vallees' strategic choices and agreements did not provide a basis for remanding the case for a new jury trial.
3. Sanctions were not warranted because the appellees had acquiesced in or agreed to procedural departures that contributed to the delay and because they requested sanctions only in their brief rather than by a separate motion.

Questions Presented

1. Whether a defendant appealing a small claims judgment in the Superior Court has a right to a second bench trial de novo.
2. Whether the Superior Court's unusual procedure for reviewing the small claims judgment could be challenged on appeal when the Vallees invited or consented to the procedural deviations.
3. Whether the appellees were entitled to sanctions when they requested sanctions only in their brief and did not file a separate sanctions motion.

Disposition

affirmed