Town of Lebanon v. East Lebanon Auto Sales LLC, 25 A.3d 950

Town of Lebanon sued East Lebanon Auto Sales LLC, Linda Corbin, and Cote alleging illegal automobile graveyard, junkyard, and subsurface wastewater violations under 30-A M.R.S. §§ 3751-3760.
Corbin is sole member of LLC and Lucky Day Auto LLC; LLC owns the Lebanon property where the business operates.
Town's CEO inspected the site multiple times (June 2009–June 2010), noting hundreds of vehicles, many unregistered or uninspected and outside, plus debris and a lack of valid permits.
The District Court entered judgment against LLC and Corbin individually for $2,000 plus $4,000 in attorney fees; the court treated Corbin and LLC as closely connected.
Appellants argued lack of proper notice/service, and that Corbin could not be personally liable; the Town contended the complaint fairly notified the parties and evidence supported liability.
The Supreme Judicial Court vacated the judgment against Corbin individually but affirmed the judgment against LLC in all other respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Corbin may be personally liable for LLC's violations	Corbin abused corporate form; equity requires piercing	No abuse or unjust result; separate liability should not be imposed	Vacate as to Corbin individually; no personal liability found
Fair notice and service regarding the complaint	Complaint provided fair notice and service issues were immaterial	Service or notice defects invalidated the judgment	Complaint adequate; service defects not prejudicial
Sufficiency of evidence to establish illegal automobile graveyard/junkyard without permit	Evidence showed multiple unregistered/uninspected vehicles and debris constituting a graveyard/junkyard	Insufficient evidence to prove violation or permit absence for all elements	Evidence adequate to support liability against LLC (except personal liability of Corbin)
Whether the LLC and Corbin were improperly treated as the same entity for purposes of liability	Operational intermixing supports liability	Separate corporate form preserved; no veil piercing	Corbin not personally liable; LLC remains liable

Dowling v. Bangor Hous. Auth., 910 A.2d 384 (Me. 2006) (clear-error review for factual determinations on issues like corporate form)
Smith v. Hawthorne, 804 A.2d 1133 (Me. 2002) (fair notice and sufficiency of service considerations)
Richards v. Soucy, 610 A.2d 268 (Me. 1992) (procedural sufficiency in state court claims)
Johnson v. Exclusive Props. Unltd., 720 A.2d 568 (Me. 1998) (twelve-factor framework for piercing corporate veil)
Town of Vassalboro v. Barnett, 13 A.3d 784 (Me. 2011) (evidence standards for land-use and permit violations)
Advanced Constr. Corp. v. Pilecki, 901 A.2d 189 (Me. 2006) (abuse of corporate form standard/clear error review applies)
Blue Star Corp. v. CKF Props., LLC, 980 A.2d 1270 (Me. 2009) (limits and evidence for individual liability separate from LLC)