David E. Major v. Wen Yih Chiang, 113 A.3d 228

Wen Yih Chiang appealed a foreclosure judgment entered in Superior Court (Penobscot County) in favor of David E. Major (and Kim Major as a party).
Chiang raised multiple challenges to the trial court’s rulings: denial of motions (new trial, continuances, remote witness testimony), evidentiary rulings, factual findings, and the overall legal determination.
On appeal Chiang repeatedly filed oversized and noncompliant briefs and appendices containing extensive “addenda” and documents not part of the trial record.
The Supreme Judicial Court repeatedly ordered Chiang to resubmit materials to comply with Maine Rule of Appellate Procedure 8 and warned that noncompliance could lead to dismissal.
Chiang failed to comply with the orders and Rule 8 (including including non-record documents and excessive addenda) despite warnings.
The court concluded that the failure to comply prevented proper appellate review and dismissed the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred on multiple procedural and evidentiary rulings	Chiang argued the trial court abused discretion and committed legal/factual error on a list of rulings	Majors argued the judgment should stand and that appellate review requires a proper record	Not reached on the merits — appeal dismissed for procedural noncompliance with M.R. App. P. 8
Whether appellate filings complied with M.R. App. P. 8	Chiang maintained his filings were adequate (implicitly challenged the court’s treatment)	Majors (and court) relied on Rule 8 requirements and prior orders directing compliance	Chiang’s briefs and appendices did not comply with Rule 8 and court orders; noncompliance prevents review
Whether the appellate court should grant leniency despite noncompliance	Chiang implicitly sought consideration of his substantive claims despite form defects	Majors and the court emphasized the necessity of orderly briefing and record for review	Court refused to excuse repeated noncompliance and dismissed the appeal
Whether dismissal is appropriate sanction for Rule 8 violations	Chiang disputed procedure but offered insufficient corrective filings	Court cited precedent that Rule 8 failures prevent proper appellate review	Dismissal affirmed as appropriate remedy for persistent noncompliance

State v. Dominique, 12 A.3d 53 (Me. 2011) (failure to comply with appellate rules can justify dismissal)
Lowd v. Dimoulas, 924 A.2d 306 (Me. 2007) (same)
State v. Ross, 841 A.2d 814 (Me. 2004) (same)