vested rights doctrine (Maine) · Go Syfert
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vested rights doctrine in Maine

16 Maine opinions name it 2 courts 2020–2025 15 in the last five years

The cases below were cited by Maine courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
NECEC Transmission LLC v. Bureau of Parks and Landsgreen
me · 2022 · cited in 14 Maine opinions naming this issue, 2022–2025
2 sentences

2025See NECEC, 2022 ME 48, ¶¶ 42, 44 , 281 A.3d 618 (“Constitutional protection of vested rights properly resides in Maine’s due process clause.”). [¶103] For reasons similar to those given in Keene and Sliney, I conclude that reliance on the vested rights doctrine in this case is misplaced and that section 752-C(3)’s retrospective operation does not violate due process.

2025See NECEC, 2022 ME 48, ¶¶ 42, 44 , 281 A.3d 618 (“Constitutional protection of vested rights properly resides in Maine’s due process clause.”). [¶103] For reasons similar to those given in Keene and Sliney, I conclude that reliance on the vested rights doctrine in this case is misplaced and that section 752-C(3)’s retrospective operation does not violate due process.

114
Liebig v. Superior Courtgreen
calctapp · 1989 · cited in 1 Maine opinions naming this issue, 2025–2025
1 sentence

2025Relying on the Laboree case and 60See Liebig, 257 Cal. Rptr. at 576 (“[S]tatutes of limitations in civil matters are procedural, not substantive.”); Doe, 119 A.3d at 502 (“[S]tatutes of limitation are presumed to apply retroactively, insofar as they are typically considered procedural, rather than substantive, legislation; thus, unless speci ically tied to a statutory right of action or unless a contrary legislative intent is expressed, the statute of limitations in effect at the time an action is iled governs the timeliness of the claim.” (quotation marks omitted)); Sheehan, 15 A.3d at 1259 (

11
Harding v. K.C. Wall Products, Inc.green
kan · 1992 · cited in 1 Maine opinions naming this issue, 2025–2025
1 sentence

2025Relying on the Laboree case and 60See Liebig, 257 Cal. Rptr. at 576 (“[S]tatutes of limitations in civil matters are procedural, not substantive.”); Doe, 119 A.3d at 502 (“[S]tatutes of limitation are presumed to apply retroactively, insofar as they are typically considered procedural, rather than substantive, legislation; thus, unless speci ically tied to a statutory right of action or unless a contrary legislative intent is expressed, the statute of limitations in effect at the time an action is iled governs the timeliness of the claim.” (quotation marks omitted)); Sheehan, 15 A.3d at 1259 (

11
Batchelder v. Tweediegreen
me · 1972 · cited in 1 Maine opinions naming this issue, 2025–2025
1 sentence

2025It is well established that the “[s]ubstantive rights of the parties are ixed at the date upon which the cause of action accrued.” Batchelder v. Tweedie, 294 A.2d 443, 444 (Me. 1972).

11
Debra Peterson v. Dept of H&Wgreen
idaho · 2014 · cited in 1 Maine opinions naming this issue, 2025–2025
1 sentence

2025Relying on the Laboree case and 60See Liebig, 257 Cal. Rptr. at 576 (“[S]tatutes of limitations in civil matters are procedural, not substantive.”); Doe, 119 A.3d at 502 (“[S]tatutes of limitation are presumed to apply retroactively, insofar as they are typically considered procedural, rather than substantive, legislation; thus, unless speci ically tied to a statutory right of action or unless a contrary legislative intent is expressed, the statute of limitations in effect at the time an action is iled governs the timeliness of the claim.” (quotation marks omitted)); Sheehan, 15 A.3d at 1259 (

11
Sheehan v. Oblates of St. Francis de Salesgreen
del · 2011 · cited in 1 Maine opinions naming this issue, 2025–2025
1 sentence

2025Relying on the Laboree case and 60See Liebig, 257 Cal. Rptr. at 576 (“[S]tatutes of limitations in civil matters are procedural, not substantive.”); Doe, 119 A.3d at 502 (“[S]tatutes of limitation are presumed to apply retroactively, insofar as they are typically considered procedural, rather than substantive, legislation; thus, unless speci ically tied to a statutory right of action or unless a contrary legislative intent is expressed, the statute of limitations in effect at the time an action is iled governs the timeliness of the claim.” (quotation marks omitted)); Sheehan, 15 A.3d at 1259 (

11
Norton v. C.P. Blouin, Inc.green
me · 1986 · cited in 1 Maine opinions naming this issue, 2022–2022
1 sentence

2022See id.

11
Thomas v. Zoning Board of Appeals of the City of Bangorgreen
me · 1978 · cited in 1 Maine opinions naming this issue, 2022–2022
1 sentence

2022Plaintiffs have not brought to the Court’s attention any case expressly holding that vested rights are a fundamental constitutional right, and the Court is not aware of any such case. 22 Appeals, 381 A.2d 643, 647 (Me. 1978); Merrill v. Eastland Woolen Mills, Inc., 430 A.2d 557 , 560 n.7 (Me. 1981); cf. Henry Paul Monaghan, Constitutional Common Law, 89 Harv.

11
NextEra Energy Resources, LLC v. Maine Public Utilities Commissiongreen
me · 2020 · cited in 1 Maine opinions naming this issue, 2022–2022
2 sentences

2022See NextEra Energy Res., LLC, 2020 ME 34, ¶ 43 , 227 A.3d 1117 . 16 The State parties argue that so long as there is a rational basis for the Initiative, the vested rights claim fails.

2022See NextEra Energy Res., LLC, 2020 ME 34, ¶ 43 , 227 A.3d 1117 . 16 The State parties argue that so long as there is a rational basis for the Initiative, the vested rights claim fails.

11
Peterson v. Town of Rangeleygreen
me · 1998 · cited in 1 Maine opinions naming this issue, 2020–2020
2 sentences

2020See Peterson v. Town ofRangeley, 1998 ME 192 , ,i 12 n. 3, 715 A.2d 930 (holding that rights vest when a municipality applies a new ordinance to an existing permit") (emphasis in original).

2020See Peterson v. Town ofRangeley, 1998 ME 192 , ,i 12 n. 3, 715 A.2d 930 (holding that rights vest when a municipality applies a new ordinance to an existing permit") (emphasis in original).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maine. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Sahl v. Town of York green
me · 2000
2 sentences

2025In NECEC, we held that a developer who had been issued a valid construction permit and had undertaken substantial construction in reliance thereon had “acquired a cognizable property right that the Maine Constitution protects from being impaired by retroactive legislation.” 2022 ME 48, ¶ 44 , 281 A.3d 618 (emphasis added); cf. Sahl v. Town of York, 2000 ME 180, ¶¶ 12-14 , 760 A.2d 266 (holding that, in the municipal zoning context, the right to continue construction vests once a developer with a validly issued, inal permit undertakes signi icant construction in good faith). 85 [¶130] Although

2025In NECEC, we held that a developer who had been issued a valid construction permit and had undertaken substantial construction in reliance thereon had “acquired a cognizable property right that the Maine Constitution protects from being impaired by retroactive legislation.” 2022 ME 48, ¶ 44 , 281 A.3d 618 (emphasis added); cf. Sahl v. Town of York, 2000 ME 180, ¶¶ 12-14 , 760 A.2d 266 (holding that, in the municipal zoning context, the right to continue construction vests once a developer with a validly issued, inal permit undertakes signi icant construction in good faith). 85 [¶130] Although

12025–2025
Proprietors of Kennebec Purchase v. Laboree green
me · 1823
1 sentence

2025Each of these cases—as well as Cof in and subsequent decisions drawing upon them— involved rights of an entirely different nature than what is at issue here. [¶121] Laboree considered the validity of a statute that would have retroactively changed the meaning of the common law doctrine of disseisin. 2 Me. at 287 .

12025–2025
Lewis v. Webb green
me · 1825
1 sentence

2025Vested Rights Jurisprudence [¶120] Our decision in NECEC chronicles the history of the vested rights doctrine, beginning with the cases of Laboree and Lewis v. Webb, 3 Me. 326 (1825), both of which are cornerstones of the Court’s reasoning here.

12025–2025
Chase Securities Corp. v. Donaldson green
scotus · 1945
1 sentence

2025There, the Court did not af irm the holding in Campbell based on a vested rights analysis but rather reasoned that a revived claim is not “per se” offensive, applying a general fairness balancing approach. 33 Id. at 316 .

12025–2025
Merrill v. Eastland Woolen Mills, Inc. green
me · 1981
1 sentence

2022Plaintiffs have not brought to the Court’s attention any case expressly holding that vested rights are a fundamental constitutional right, and the Court is not aware of any such case. 22 Appeals, 381 A.2d 643, 647 (Me. 1978); Merrill v. Eastland Woolen Mills, Inc., 430 A.2d 557 , 560 n.7 (Me. 1981); cf. Henry Paul Monaghan, Constitutional Common Law, 89 Harv.

12022–2022
Kittery Retail Ventures, LLC v. Town of Kittery green
me · 2004
1 sentence

2022However, the doctrine of vested rights, even in the municipal setting, is an equitable concept. 23 Kittery Retail Ventures, 2004 ME 65, ¶¶ 24-27 .

12022–2022
Baxter v. Waterville Sewerage District green
me · 1951
1 sentence

2022The Initiative is an exercise of state “police power” to protect the environment. 19 “The exercise of the police power in such cases violates no constitutional guarantee against the impairment of vested rights or contracts.” Baxter, 79 A.2d at 589 .

12022–2022
State of Maine v. Dan Brown green
me · 2014
2 sentences

2022State v. Brown, 2014 ME 79, ¶ 23 , 95 A.3d 82 .

2022State v. Brown, 2014 ME 79, ¶ 23 , 95 A.3d 82 .

12022–2022

Statutes the citing opinions construe

ME § Me. Rev. Stat. tit. 14, § 752-C (13)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WA 79 (1978–2025) CA 47 (1975–2026) IL 35 (1968–2021) NY 23 (1963–2026) PA 21 (1979–2026) ME 16 (2020–2025) TX 14 (2006–2021) VT 12 (1991–2026) MD 12 (1993–2024) OR 10 (2007–2019) NC 9 (1997–2025) DE 7 (2015–2022) NM 7 (1995–2010) MN 6 (1980–2016) KS 6 (1995–2018) NJ 5 (1993–2020) OH 5 (1990–2014) VA 4 (1996–2024) SD 3 (1992–2022) IA 3 (2009–2026) AK 3 (1968–1994) WI 3 (1995–2017) FL 3 (1967–2016) TN 3 (1995–2024) LA 2 (1970–2013) UT 2 (2005–2020) CT 2 (1986–2015) NV 2 (1984–1996) NH 2 (1980–1995) MI 2 (1977–1982) IN 2 (2007–2016) HI 2 (1982–2005)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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