103 A.3d 212
Me.2014Background
- Margaret C. Gray died in 2007, leaving three Maine real properties and equal shares to Ernest L. Gray III and Elizabeth Tasker.
- Elizabeth filed Margaret’s will in 2010 and sought appointment as personal representative; Joel A. Dearborn Sr. was appointed as personal representative after Ernest objected.
- Elizabeth, on January 19, 2011, asserted a claim against the estate for 40,871.25 to reimburse expenses she paid maintaining the properties since 2007.
- A May 14, 2012 probate hearing showed Elizabeth provided evidence of payments from 2007–2012; the court awarded her 45,419.46.
- On remand (2013) the Supreme Judicial Court instructed applying 18-A M.R.S. § 3-803(b) to claims arising after death and to consider all raised claims; Elizabeth later argued unjust enrichment falls outside § 3-803(b).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 3-803(b) apply to unjust enrichment claims? | Tasker argues unjust enrichment falls outside § 3-803(b). | Gray contends § 3-803(b) covers all post-death claims, including unjust enrichment. | Yes; § 3-803(b) covers all post-death claims, including unjust enrichment. |
Key Cases Cited
- Estate of Leavitt, 1999 ME 102 (Me. 1999) (broadly defines 'claim' under Probate Code)
- Estate of Staples, 1996 Me. 672 A.2d 99 (Me. 1996) (creative labeling cannot exempt a claim from Probate Code)
- Estate of Miller, 2008 ME 176 (Me. 2008) (unjust enrichment claim against a decedent's son applied six-year limit)
- Estate of Weatherbee, 2014 ME 73 (Me. 2014) (statute of limitations de novo review standard)
- MaineToday Media, Inc. v. State, 2013 ME 100 (Me. 2013) (plain-language interpretation of statutes)
- Estate of Leavitt, 733 A.2d 348 (Me. 1999) (broad definition of 'claim' under Probate Code)