Eric Badler v. University of Maine System, 277 A.3d 379

On November 4, 2017, Eric Badler, a baker employed by Sodexo, injured his right index finger using an industrial motorized kitchen mixer owned and supplied by the University of Maine System at the Farmington campus; an incompatible bowl dislodged and its handle cut his finger, causing severe injury and lasting impairment.
Badler sued the University for negligence, arguing the University negligently provided a dangerous mixer.
The University moved for summary judgment asserting immunity under the Maine Tort Claims Act (MTCA), 14 M.R.S. §§ 8101–8118, because governmental entities are generally immune from tort suit except where the MTCA expressly waives immunity.
Badler countered that the mixer fell within the MTCA waiver for negligent ownership, maintenance, or use of "other machinery or equipment, whether mobile or stationary" (14 M.R.S. § 8104‑A(1)(G)).
The Superior Court granted summary judgment for the University, concluding the mixer was not covered by the § 8104‑A(1)(G) exception; Badler appealed and the Maine Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the industrial kitchen mixer falls within the MTCA § 8104‑A(1)(G) "other machinery or equipment" exception to governmental immunity	Badler: the mixer is motorized "other machinery or equipment," so the MTCA waiver applies	University: the catch‑all exception is limited by ejusdem generis to items comparable to A–F (transportation‑related, mobile, public contact), and a kitchen mixer is not of that class	Court: Affirmed immunity — mixer is not within § 8104‑A(1)(G); exceptions to MTCA are construed narrowly and the mixer’s risk/profile is not comparable to enumerated items, so waiver does not apply

McNally v. Town of Freeport, 414 A.2d 904 (Me. 1980) (applies ejusdem generis and a risk‑comparison test to § 8104‑A(1)(G))
New Orleans Tanker Corp. v. Dep’t of Transp., 728 A.2d 673 (Me. 1999) (limits § 8104‑A(1)(G) to items comparable to enumerated transportation‑related equipment; notes common qualities of A–F)
J.R.M., Inc. v. City of Portland, 669 A.2d 159 (Me. 1995) (interpreting § 8104‑A(1)(G) in context of municipal equipment)
Petillo v. City of Portland, 657 A.2d 325 (Me. 1995) (discusses machinery/equipment exception in MTCA context)
Harris v. City of Old Town, 667 A.2d 611 (Me. 1995) (applies comparative risk analysis under § 8104‑A(1)(G))
Klein v. Univ. of Me. Sys., 271 A.3d 777 (Me. 2022) (recites summary judgment standard and strict construction of MTCA waivers)
McDonald v. City of Portland, 239 A.3d 662 (Me. 2020) (reviews question of immunity as a question of law on undisputed facts)