293 A.3d 445
Me.2023Background
- Cole Bridges and Candy Littell married in 1992; Littell filed for divorce in 2019 (dismissed) and again in 2020; final hearing concluded Feb. 1, 2022.
- The couple are 50/50 members of Cole G. Bridges Wild Blueberry LLC (Wild Blueberry LLC); they also owned various real and personal property used in family blueberry businesses.
- Two airplanes were central: a Cessna (previously owned by Bridges Wild Blueberry Co., Inc., later transferred to Cole, then to Cole’s mother) and an Aviat Husky (marital in character but also transferred to Cole’s mother).
- The District Court classified the Cessna as marital, valued it at $150,000 (the Aviat at $125,000), awarded both planes to Bridges, and ordered Wild Blueberry LLC dissolved and its assets sold.
- On appeal Bridges challenged the court’s valuation/classification of the Cessna and argued the court lacked jurisdiction to dissolve Wild Blueberry LLC and to distribute assets owned by nonparties (Bridges’s mother and potentially the LLC). The Supreme Judicial Court vacated the property-distribution and LLC-dissolution portions of the judgment and remanded.
Issues
| Issue | Littell's Argument | Bridges' Argument | Held |
|---|---|---|---|
| Whether the District Court could dissolve Wild Blueberry LLC as part of the divorce | Court may divide marital property and address membership interests; dissolution appropriate to effectuate equitable distribution | Court lacked personal jurisdiction over the LLC (a nonparty distinct from the spouses) and therefore could not order dissolution | The court lacked jurisdiction to dissolve the LLC; dissolution order vacated |
| Whether the court could order distribution of airplanes owned by nonparties | Airplanes were marital assets (or assets of the spouses’ business) and could be set aside in division | At time of judgment the planes were owned by Bridges’s mother (and/or the LLC), nonparties not before the court, so court lacked power to order their distribution | Court erred in distributing property owned by nonparties; property distribution vacated |
| Whether the Cessna was marital or nonmarital property | Cessna was marital (acquired during marriage and tied to family businesses) | Cessna was acquired by bequest or gift to Bridges and thus nonmarital | Court’s finding that the Cessna was marital was not clearly erroneous; Bridges failed to rebut the marital presumption |
| Proper valuation of the Cessna | Littell contested lower valuation; sought alternative valuation | Bridges testified as experienced pilot/mechanic valuing it at $150,000; argued court erred if it deviated | Court’s acceptance of $150,000 valuation was not clearly erroneous and stands for valuation purposes on remand |
Key Cases Cited
- Howard v. Howard, 2 A.3d 318 (Me. 2010) (District Court may determine spouses’ ownership interests but lacks personal jurisdiction over nonparty LLCs)
- Ahern v. Ahern, 938 A.2d 35 (Me. 2008) (Maine LLC statute does not permit dissolution of an LLC solely because of a member’s divorce)
- Robinson v. Robinson, 751 A.2d 457 (Me. 2000) (narrow exception allowing divorce court to treat a business as essentially the same party when it is represented in all but name)
- King v. King, 66 A.3d 593 (Me. 2013) (party must bring separate action against third party to resolve property disputes with nonparties)
- Wandishin v. Wandishin, 976 A.2d 949 (Me. 2009) (standard of review for classification and valuation of property; courts may credit parties’ valuation testimony)
- Harper v. Harper, 169 A.3d 385 (Me. 2017) (court may account for economic misconduct that diminished the marital estate when reallocating property)
- Mitchell v. Mitchell, 284 A.3d 89 (Me. 2022) (on remand, trial court may reevaluate property distribution)