Judicial data via CourtListener (Free Law Project). Social links via Wikidata.
Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
Opinions apply specific statutory text without resort to purpose, as in United States v. Dwelley rejecting defenses under 20 U.S.C. § 1091a and in Belanger v. Healthsource dismissing state claims as preempted by ERISA text. United States v. Dwelley ↗ Belanger v. Healthsource of Main… ↗
Deference to government powerSkepticism of government power
Rulings uphold government actors' conduct when supported by reasonable suspicion or warrant information, as in Greenleaf v. Cote sustaining a principal's search and Miller v. Kennebec County granting summary judgment to officers and jails. Greenleaf Ex Rel. Greenleaf v. C… ↗ Miller v. Kennebec County ↗
Affiliations
District Court, D. Maine — appointed by George H.W. Bush
Party: Republican →B.A., Bates CollegeBA, Bates CollegeJD, University of Chicago
In this case, John and Margaret Hall sued Maine Municipal Employees Health Trust (MMEHT) in state court on behalf of their daughter, alleging breach of contract and violations of Maine’s Unfair Claims Settlement Practices Act after MMEHT terminated speech therapy benefits. MMEHT removed the case to federal court, arguing that the claims were preempted by ERISA because the Trust was an employee benefit plan. The court granted the Halls’ motion to remand, holding that MMEHT qualifies as a governmental plan exempt from ERISA. The reasoning centered on the Trust’s establishment by a municipal association for mostly governmental employers, with only a de minimis number of non-governmental participants, and its governance structure tied to public entities.
In Bloom v. Crook, plaintiff Annalee Bloom, a former assistant district attorney, alleged sex and religion discrimination by her supervisors and the state of Maine under Title VII and the Maine Human Rights Act after her dismissal. Maine moved to dismiss the claims against it under Rule 12(b)(6), arguing it was not Bloom's employer because district attorneys control hiring, firing, and daily supervision of assistants. The court denied the motion, applying a control-based test from First Circuit precedent that considers factors including authority over compensation, benefits, and employee numbers. It concluded that Maine's role in legislative appropriations for salaries and approvals by the Attorney General and Governor could establish sufficient involvement to make the state an employer at this stage, allowing the case to proceed to discovery.
This case involved a claim by a student, Jennifer Greenleaf, through her father, that her school's principal violated her Fourth Amendment rights by conducting a search for evidence of alcohol consumption. Following a bench trial, the court ruled in favor of the defendant principal, concluding that the search did not violate the Constitution. The decision was based on the search being justified at its inception due to a reliable student informant's report of beer drinking and reasonable suspicion of violations, and reasonable in scope as it was conducted privately with consent, without physical contact, and limited to areas where evidence might be found, per the standards in New Jersey v. T.L.O.
David Bishop sued his employer, Bell Atlantic, in state court alleging retaliation and discrimination in employment under the Maine Whistleblowers’ Protection Act and Maine Human Rights Act after he reported an alleged assault by his supervisor and filed related charges with the Maine Human Rights Commission. Bell Atlantic removed the case to federal court and moved to dismiss or for summary judgment, arguing that the claims were preempted by Section 301 of the federal Labor Management Relations Act because they implicated a collective bargaining agreement. The court treated the motion as one for summary judgment and granted it in part and denied it in part. It held that Bishop’s MHRA retaliation claim under 5 M.R.S.A. § 4572(1)(E) was not preempted because resolving it did not require interpreting the CBA, while noting that other potential bases for the claim might be analyzed differently. The court retained jurisdiction on diversity grounds even without federal-question jurisdiction over the state-law claim.
Susan Belanger sued her health insurer Healthsource and its mental health benefits administrator CMG after they initially denied coverage for her inpatient psychiatric treatment, leading to her discharge from the hospital; she alleged negligence, breach of contract, unfair trade practices, and ERISA violations. The court dismissed the three state-law claims with prejudice, holding that they were preempted by ERISA as alternative enforcement mechanisms that would frustrate uniform federal administration of employee benefit plans. The ERISA claim was dismissed without prejudice because the complaint failed to allege exhaustion of administrative remedies for unpaid outpatient benefits or that either defendant was the plan administrator subject to penalties for withholding information.
The case involved parents suing a Maine school district, its interim superintendent, and a principal for failing to investigate multiple reports of a probationary teacher's inappropriate relationships with male high school students, which allegedly enabled the teacher to sexually harass their 15-year-old son after an off-campus incident involving alcohol. Plaintiffs asserted claims under Title IX, 42 U.S.C. § 1983, the Maine Human Rights Act, and common-law negligence. On the defendants' motion for summary judgment, the court granted the motion in part and denied it in part, dismissing the § 1983 claims against the individual officials because the harassment did not occur under color of state law and some other claims on preemption or immunity grounds, while allowing certain Title IX and negligence claims to proceed due to disputed facts about whether prior reports should have prompted action that might have prevented the misconduct.
