MAINE SUPREME JUDICIAL COURT Reporter of Decisions

Decision: 2025 ME 82
Docket: Ken-25-53
Argued: July 15, 2025
Decided: August 26, 2025

Panel: STANFILL, C.J., and MEAD, HORTON, LAWRENCE, and DOUGLAS, JJ.

MAINE STATE CHAMBER OF COMMERCE et al.

v.

DEPARTMENT OF LABOR et al.

MEAD, J.

[¶1] This case is before us on report from the Superior Court (Kennebec

County, Daniel Mitchell, J.) pursuant to M.R. App. P. 24(a). The report submits

three questions of law regarding the legality and constitutionality of rules

promulgated by the Maine Department of Labor in administering the Paid

Family and Medical Leave Act, P.L. 2023, ch. 412, § AAA-7 (effective Oct. 25,

2023) (codified as subsequently amended at 26 M.R.S. §§ 850-A to 850-R

(2025)), which established a Paid Family and Medical Leave (PFML) program.

We accept the report and determine that the Department’s rules do not conflict

with the Act and do not constitute a taking of private property for public use

under either the Maine Constitution or the United States Constitution.

2

I. BACKGROUND

[¶2] The facts are drawn from an agreed statement of facts and five

exhibits submitted by the parties as part of the consented-to motion to report

to the Law Court. See Payne v. Sec’y of State, 2020 ME 110, ¶ 4, 237 A.3d 870.

[¶3] In 2023, the Legislature enacted the PFML program. See 26 M.R.S.

§§ 850-A to 850-R. Starting May 1, 2026, the Act allows a covered individual to

take up to twelve weeks of leave from their employment for certain qualifying

reasons. Id. §§ 850-B(2), 850-P. The PFML program pays the covered

individual through a state-run fund that accumulates deposits, called

“contributions,” “premiums,” or “premium contributions,” made into the fund

by employers1 and self-employed individuals who elect to be covered by the

program. See id. § 850-A(7) (defining “contributions” as “the payments

remitted by an employer or self-employed individual to the fund, as required

by this subchapter”); id. § 850-F (requiring that employers and self-employed

individuals pay “premiums” or “premium contributions” and requiring

employers to remit “employer contribution reports and premiums”). Maine

1The starting premium is 1% of wages. 26 M.R.S. § 850-F(3)(A). An employer with 15 or more

employees may deduct up to half of the premium attributable to an employee from the employee’s
wages and must remit to the Department the entire premium. Id. § 850-F(5)(A). An employer with
fewer than 15 employees must remit to the Department an amount equal to half of the premium and
may deduct from an employee’s wages all of the premium remitted. Id. § 805-F(5)(B). For ease of
discussion, this opinion will describe all premiums as being paid by the employer.
 3

businesses were required to start remitting quarterly premiums into the fund

on January 1, 2025. Id. § 850-F(2).

[¶4] The PFML program allows private employers to apply to the

Department to substitute an approved private plan for the PFML program. Id.

§ 850-H(1). The statute clarifies that “[i]n order to be approved, a private plan

must confer rights, protections and benefits substantially equivalent to those

provided to employees under this subchapter [26 M.R.S. §§ 850-A to 850-R].”

Id. If a private employer substitutes a private plan for the PFML program, the

employer “is not required to remit premiums . . . to the fund.” Id. § 850-F(8).

[¶5] Sections 850-H(8) and 850-Q direct the Department to adopt rules

to implement the PFML program by January 1, 2025. Throughout 2024, the

Department engaged in a rulemaking process. After two rounds of comments,

the Department finalized its rules on December 4, 2024, and the rules took

effect on January 1, 2025. See 12-702 C.M.R. ch. 1 (effective Jan. 1, 2025).

[¶6] At issue in this case are the Department’s promulgated rules related

to premiums and the substitution of private plans for the program. The PFML

program and the Department’s rules required all employers to begin remitting

premiums into the fund in January 2025. 26 M.R.S. § 850-F(2); 12-702 C.M.R.

ch. 1, § X(B). Rule 12-702 C.M.R. ch. 1, § XIII(A)(2) allows employers to apply
4

for approval of a private plan after April 1, 2025, which is the first day of the

second quarter of 2025. The Department instituted this delay in the interest of

administrative feasibility because it was the Department’s understanding that

it would take insurance companies three to four months after the final rules

were issued to write private policies that would satisfy the requirement that

the coverage of the private plan be substantially equivalent to the PFML

program (the “substantial-equivalence requirement”). If a private plan is

approved, “[t]he exemption from the obligation to pay premiums begins on the

first day of the quarter in which the substitution is approved.” Id. § XIII(A)(4).

The rules clarify that “[t]he employer is responsible for premiums provided

under the Act and this rule until the effective date of [the] exemption[,] and

premiums owed prior to the effective date of [the] exemption must be remitted

and are non-refundable.” Id. § XIII(A)(4)(b). The Department explained in a

response to comments that this component of the application process “was

developed balancing the interest of employers and the interest of establishing

a fiscally sound Paid Family and Medical Leave Fund.”

[¶7] Following the adoption of the rules, insurers began writing policies

that would satisfy the substantial-equivalence requirement and, if approved,

would allow private employers to quickly substitute a pre-approved private

 5

plan for the PFML program. See id. § XIII(D). The Maine Bureau of Insurance

and the Department would then review these policies, which were expected to

be approved by April 1, 2025. Fourteen insurance companies submitted

proposed private plans to the Bureau and Department for review. Starting on

April 1, 2025, employers began to apply to the Department to offer substitute

plans using pre-approved private plans.2 Since January 2025, employers have

been remitting premiums to the fund.3

[¶8] On January 13, 2025, the Maine State Chamber of Commerce and

Bath Iron Works (BIW) brought a complaint against the Department and its

Commissioner, Laura A. Fortman, to challenge 12-702 C.M.R. ch. 1,

§ XIII(A)(4)(b). Both plaintiffs sought relief pursuant to 5 M.R.S. § 8058(1)

(2025) to have the regulation declared invalid. BIW, individually, brought

several claims: (a) a claim pursuant to M.R. Civ. P. 80C and 5 M.R.S.

§§ 11001-11008 (2025) for a “judgment that 12-702 C.M.R. ch. 1,

2 The parties dispute the nature of the Department’s approval of employers’ applications for
pre-approved substitute private plans. The plaintiffs describe the Department’s approval as a mere
formality. The Department acknowledges that the approval of pre-approved substitute private plans
will be “fairly streamlined,” but contends that section 850-H of the Act requires the Department to
independently review applications to substitute private plans and that those approvals are not
automatic.
3 At the time of the consented-to motion to report the questions to the us, Bath Iron Works
estimated that it would remit approximately $620,000 in nonrefundable premiums for the first
quarter of 2025.
6

§ XIII(A)(4)(b) is null and void on the basis that it violates the governing

statutory provision and thwarts the Legislature’s intent in establishing the

PFML”; (b) a claim under 42 U.S.C.A. § 1983 (Westlaw through Pub. L.

No. 119-33), contending that the Department’s regulations violated its Fifth

Amendment right against unconstitutional takings; and (c) a claim seeking

compensation on the ground that the rule is an inverse condemnation that

violates article I, § 21 of the Maine Constitution.

[¶9] On February 5, 2025, the plaintiffs filed a consented-to motion to

report questions to the Law Court pursuant to M.R. App. P. 24(a) with an

agreed-upon statement of facts and exhibits. The questions presented were the

following:

(I) Have Plaintiffs proven, on the stipulated record, pursuant to

5 M.R.S. § 8058 (2025) that 12-702 C.M.R. ch. 1, § XIII(A)(4)(b)
conflicts with the Paid Family Medical Leave Act, 26 M.R.S.
§§ 850A-850-R (2025), or that 12-702 C.M.R. ch. 1, § XIII(A)(4)(b)
is arbitrary and capricious or otherwise not in accordance with
law?

(II) Have Plaintiffs proven, on the stipulated record, that 12-702

C.M.R. ch. 1, § XIII(A)(4)(b) constitutes a cognizable claim of taking
of private property for public use, without just compensation, in
violation of article I, section 21 of the Maine Constitution?

(III) Have Plaintiffs proven, on the stipulated record, that 12-702

C.M.R. ch. 1, § XIII(A)(4)(b) constitutes a cognizable claim of taking
of private property for public use, without just compensation, in
 7

violation of the Fifth Amendment of the United States Constitution,

made applicable to the States through the Fourteenth Amendment?

The court issued an order in which it determined that the three questions

presented were of “substantial importance not only to the parties but also other

members of the public” and reported the questions to us.

II. DISCUSSION

A. Reported Questions

[¶10] We begin by addressing issues inherent in the vehicle by which

this matter reaches us—a report pursuant to M.R. App. P. 24(a).4 Because

Rule 24 exists as an exception to the final judgment rule and should be used

sparingly, see Liberty Ins. Underwriters v. Est. of Faulkner, 2008 ME 149, ¶ 5, 957

A.2d 94, we must “independently determine whether acceptance of the report

is consistent with our basic function as an appellate court or would improperly

place us in the role of an advisory board due to the lack of a final trial court

4 Maine Rule of Appellate Procedure 24(a) provides,

(a) Report by Agreement of Important or Doubtful Questions. When the trial

court is of the opinion that a question of law presented to it is of sufficient importance
or doubt to justify a report to the Law Court for determination, it may so report when:

(1) all parties appearing agree to the report;

(2) there is agreement as to all facts material to the appeal; and

(3) the decision thereon would, in at least one alternative, finally dispose of the action.
8

judgment to review.” Me. Senate v. Sec’y of State, 2018 ME 52, ¶ 14, 183 A.3d

749. We consider the following factors in determining whether to accept a

report: “(1) whether the question reported is of sufficient importance and

doubt to outweigh the policy against piecemeal litigation; (2) whether the

question might not have to be decided because of other possible dispositions;

and (3) whether a decision on the issue would, in at least one alternative,

dispose of the action.” Conservatorship of Emma, 2017 ME 1, ¶ 7, 153 A.3d 102

(quotation marks omitted); see id. ¶¶ 5, 8-13 (determining that all three factors

militated against accepting the reported questions related to the availability of

court records and docket information in electronic format because it was a

question of policy that could be answered through a rulemaking or statutory

amendment, it would not dispose of the action, and the issue may have been

moot because of independent legal authority).

[¶11] Here, the conditions specified in M.R. App. P. 24(a)(1)-(3) are met:

the parties agree to the report; there is agreement as to all material facts; and a

decision would, in at least one alternative, dispose of the action. The questions

presented in the report are of sufficient importance to meet Rule 24(a)’s

standard because a determination of any of these questions affects any Maine

business that intends to provide a substitute plan, implicates the validity of a

 9

major statewide benefits program that is in the process of being implemented,

and could affect the ability of the Department to fund the PFML program.

Accordingly, we accept the reported questions.

B. Question I

[¶12] The first reported question asks whether the Department has

exceeded its statutory authority by promulgating rules that are contrary to law.

[¶13] “State agencies may exercise only that power which is conferred

upon them by law.” Molasses Pond Lake Ass’n v. Soil & Water Conservation

Comm’n, 534 A.2d 679, 681 (Me. 1987). “Under an enabling statute, a public

body or a state agency may employ powers that are expressly granted, powers

that are reasonably inferred from powers expressly granted, and powers that

are essential to give effect to powers expressly granted.” Calnan v. Hurley, 2024

ME 30, ¶ 9, 314 A.3d 267 (quotation marks omitted). An agency rule that

conflicts with the language of the statute exceeds the statutory authority of the

agency. See Lydon v. Sprinkler Servs., 2004 ME 16, ¶ 15, 841 A.2d 793. Title

5 M.R.S. § 8058(1) provides a three-part analysis by which we assess whether

a rule is valid:

First, if we find that a rule exceeds the rule-making authority of the

agency or is void for the agency’s failure to follow the procedural
processes of the Maine Administrative Procedure Act, we must
declare the rule invalid. Second, we review any other alleged
10

procedural errors, and we may invalidate the rule only if we find

the error to be substantial and related to matters of such central
relevance to the rule that there is a substantial likelihood that the
rule would have been significantly changed if the error had not
occurred. Finally, if a procedural error does not invalidate the rule,
we review the rule substantively to determine whether the rule is
arbitrary, capricious, an abuse of discretion or otherwise not in
accordance with the law.

Bocko v. Univ. of Me. Sys., 2024 ME 8, ¶ 26, 308 A.3d 203 (alterations, citations,

and quotation marks omitted).

[¶14] We employ a two-part analysis when we review an agency’s

interpretation of a statute it administers. See Calnan, 2024 ME 30, ¶ 11, 314

A.3d 267. “If the statute is unambiguous, we give effect to the plain meaning of

the statute.” Id. If the statute is ambiguous, we determine whether the agency’s

interpretation was reasonable and defer to that interpretation so long as it is

within the agency’s expertise. See id.

[¶15] The relevant statutory provisions are as follows: Section 850-F(2)

provides, “Beginning January 1, 2025, for each employee, an employer shall

remit employer contribution reports and premiums in the form and manner

determined by the administrator.” The same section later provides, “An

employer with an approved private plan under section 850-H is not required to

remit premiums under this section to the fund.” 26 M.R.S. § 850-F(8).

Section 850-H(1) clarifies, “In order to be approved, a private plan must confer
 11

rights, protections and benefits substantially equivalent to those provided to

employees” under the program. Finally, the Legislature gave the Department

until January 1, 2025, to “adopt rules as necessary to implement” the PFML

program. Id. § 850-Q.

[¶16] The Act’s plain language does not exempt employers from

remitting premiums until the Department approves a substitute private plan.

Thus, section 850-F(8) creates a forward-looking, prospective exemption that

was not intended to start immediately on January 1, 2025. The Legislature gave

the Department until January 1, 2025, to adopt rules related to substitute

private plans. The use of this date—which is when employers were required to

start remitting premiums as well as the latest that the Department could adopt

rules—supports the idea that the Legislature recognized that there would

inevitably be some gap between when employers were required to start

remitting premiums into the fund and when employers obtained approvals for

private plans. The language “[i]n order to be approved” in section 850-H(1)

indicates that the statute requires the Department to undertake an

independent review of each private plan. Because this review process is not

automatic and immediate, the statute plainly contemplates some period when

all employers are required to remit premiums into the fund.

12

[¶17] Using this statutory framework, the Department adopted the

following rules (among others): (1) an employer, regardless of whether it takes

all steps to apply and fully intends to provide substitute a private plan, is

required to pay nonrefundable premiums until the effective date of exemption,

see 12-702 C.M.R ch. 1, § XIII(A)(4)(b); (2) the exemption from the obligation

to pay premiums begins on the first day of the quarter in which the substitution

is approved, id. § XIII(A)(4); and (3) an employer may not apply to the

Department to substitute a private plan until after April 1, 2025, which

corresponds with the start of the second quarter of 2025, see id. § XIII(A)(2).

As a result, these regulations work together to require all employers to pay

nonrefundable premiums into the fund for the first quarter of 2025.

[¶18] Accordingly, the Department did not exceed its statutory authority

and did not promulgate rules that are contrary to law. See 26 M.R.S. § 850-Q.

The statute is unambiguous regarding whether the Department can require an

employer to remit nonrefundable premiums into the fund while also delaying

it from applying to substitute a private plan until the start of the second quarter

of 2025.

[¶19] Requiring an employer to begin remitting nonrefundable

premiums into the fund in January 2025 is consistent with 26 M.R.S

 13

§ 850-F(2)’s requirement that starting on January 1, 2025, “an employer shall

remit . . . premiums in the form and manner determined by the administrator.”

Nothing in the statute mandates or even anticipates refunds for employers that

eventually obtain an exemption from the requirement to remit premiums.

[¶20] Furthermore, the Department’s nonrefundable-premium rule

reasonably furthers the Legislature’s directive to implement and develop a

fiscally sound fund. See id. § 850-P (“[T]he authority shall conduct an actuarial

study to ensure the solvency of the fund. . . .”). Based on the experience of other

states in implementing programs for paid family and medical leave, the

Department was concerned about employers committing to substitute plans

through “declarations of intent” or otherwise avoiding remitting premiums

during the lead-up period and jeopardizing the solvency of the fund. By

clarifying that the premiums are nonrefundable, the DOL reasonably avoided

this problem and furthered its legitimate interest in rolling out a fiscally sound

fund.

[¶21] In addition, the Department’s rule delaying employers from

applying until after April 1, 2025, for substitute private plans, 12-702 C.M.R ch.

1, § XIII(A)(2), was the product of reasonable administrative considerations.

Based on representations from the insurance industry, the Department

14

determined that it would take several months for the insurance industry to

study the rules, draft coverage policies, and submit to the Bureau and

Department for preapproval plans that were substantially equivalent to the

PFML program. The PFML program is structured using a system of quarterly

premium payments, see id. § 850-F(2) (“Employer contribution reports and

premiums must be remitted quarterly.”), and therefore the Department

reasonably designated April 1, 2025, the start of the second quarter of 2025, as

the date on which exemptions would begin, which created only a small window

of time before the exemption process was rolled out. Further, by selecting this

date, the Department avoided administrative problems related to employers

applying for the exemption before private substitute plans had been

pre-approved.

[¶22] Finally, the rules allowing employers with approved private plans

to cease paying premiums into the fund as early as April 1, 2025, despite the

fact that coverage will not be available until 2026, inures to the benefit of those

employers. All other employers must pay premiums into the fund for all of

2025, even though the coverage under the PFML program will not start until

2026.
 15

[¶23] We conclude that the rules do not conflict with the Act. The

Department’s rules reasonably implement the PFML program and the

exemption for private substitute plans. Accordingly, the Department did not

exceed its statutory authority. See 5 M.R.S. § 8058. The plaintiffs raise no other

argument to suggest that there was some procedural error or that the rule is

“arbitrary, capricious, an abuse of discretion or otherwise not in accordance

with the law,” and, in any event, we conclude that it is not. See Bocko, 2024 ME

8, ¶ 32, 308 A.3d 203.

C. Questions II and III

[¶24] The second and third questions ask whether the Department

violated article I, § 21 of the Maine Constitution or the Fifth and Fourteenth

Amendments to the United States Constitution by adopting rules that constitute

a taking of property for a public purpose without providing just compensation.

[¶25] “The party challenging [a] regulation bears the heavy burden of

overcoming [the] presumption of constitutionality.” Davis v. Sec’y of State, 577

A.2d 338, 341 (Me. 1990). The final clause of the Fifth Amendment provides,

“[N]or shall private property be taken for public use, without just

compensation.” U.S. Const. amend. V. Similarly, the Maine Constitution

provides that “[p]rivate property shall not be taken for public uses without just
16

compensation; nor unless the public exigencies require it.” Me. Const. art. I,

§ 21.

[¶26] A regulation that “‘goes too far’” in adversely affecting a private

property interest “‘will be recognized as a taking.’” MC Assocs. v. Town of Cape

Elizabeth, 2001 ME 89, ¶ 4, 773 A.2d 439 (quoting Pa. Coal Co. v. Mahon, 260

U.S. 393, 415 (1922)). Whether a regulation has gone too far “depends largely

‘upon the circumstances of the case,’” considering factors such as “‘the

economic impact of the regulation on the claimant, the extent to which the

regulation has interfered with distinct investment-backed expectations, and

the character of the governmental action.’” Id. ¶ 5 (quoting Penn Cent. Transp.

Co. v. City of New York, 438 U.S. 104, 124 (1978) (alterations, ellipses, and

quotation marks omitted)). Impermissible regulatory takings can occur for

both tangible and intangible property, and a tax or fee can constitute a

regulatory taking under some circumstances. See Me. Beer & Wine Wholesalers

Ass’n v. State, 619 A.2d 94, 97 (Me. 1993); Tyler v. Hennepin Cnty., Minn., 598 U.S.

631, 639 (2023); Koontz v. St. Johns River Water Mgmt. Dist., 570 U.S. 595, 613

(2013).
 17

1. Voluntary Participation

[¶27] No regulatory taking occurs when a property owner voluntarily

participates in a regulated program. See Yee v. City of Escondido, 503 U.S. 519,

527-28 (1992) (holding that a rent-control ordinance did not constitute a

taking because the land owners voluntarily rented their land to tenants);

Garelick v. Sullivan, 987 F.2d 913, 916-17 (2d Cir. 1993) (holding that a law that

limited the amount physicians could charge to Medicare beneficiaries under a

certain program was not a taking because the physicians opted to provide

services to Medicare beneficiaries).

[¶28] Here, the Legislature developed the PFML program to ensure that

all employees in Maine can obtain PFML benefits. See 26 M.R.S. §§ 850-B,

850-F(2). The Legislature then gave employers the option, and the

corresponding burden, to apply to substitute a private plan. See id. §§ 850-F(8),

850-H(1). This policy structure confirms that an employer’s use of a substitute

private plan is fully voluntary.

[¶29] Section 850-F(8) of the Act explicitly exempts employers with

approved private plans from remitting premiums but says nothing about

employers that have not been approved. Although the employees of BIW may

never directly benefit from BIW’s premium payments given the approval of
18

BIW’s private plan, the Department initially assumes that every employer will

participate in the statutory PFML program. This administrative presumption

is consistent with the Act’s plain language. The Department reasonably

determined that it cannot administer the PFML program based on an

assumption that every employer that intends to apply to substitute a private

plan will actually do so or that every application will be approved.

Furthermore, the rule is rationally related to the Department’s goals of

ensuring an administratively smooth implementation of the PFML program and

that the PFML fund is solvent. See Me. Beer & Wine Wholesalers Ass’n, 619 A.2d

at 99 (“[G]overnment regulation that exacts costs from private business is

permissible as long as it is a reasonable use of the state’s police power.

Reasonableness . . . requires that the purpose of the enactment be in the interest

of the public welfare and that the methods utilized bear a rational relationship

to the intended goals.” (citation omitted)).

2. Property Interest

[¶30] Furthermore, a regulation is subject to a Takings Clause analysis

only if a specific, identifiable property right or interest is at stake. See id. at

97-98; E. Enters. v. Apfel, 524 U.S. 498, 541-42 (1998) (Kennedy, J., concurring).

Thus, “a Takings Clause issue can arise only after a plaintiff’s property right has
 19

been independently established.” Parella v. Ret. Bd. of R.I. Emps.’ Ret. Sys., 173

F.3d 46, 58 (1st Cir. 1999). Therefore, the mere “imposition of an obligation to

pay money” does not constitute an unconstitutional taking of property when it

does not involve an identifiable property interest. See Commonwealth Edison

Co. v. U.S., 271 F.3d 1327, 1340 (Fed. Cir. 2001); Swisher Int’l, Inc. v. Schafer, 550

F.3d 1046, 1054-1055 (11th Cir. 2008) (concluding that imposing an obligation

to contribute to a fund that would buy out tobacco farmers did not constitute

an unconstitutional taking). In Eastern Enterprises v. Apfel, five justices of the

U.S. Supreme Court agreed that no unconstitutional taking occurred when

Congress required an employer to pay health care premiums for retired miners

who had previously worked for the employer when it was in the coal business.

524 U.S. at 540 (concurring and dissenting opinions). Justice Kennedy

reasoned that the legislation “does not appropriate, transfer, or encumber an

estate in land (e.g. a lien on a particular piece of property), a valuable interest

in an intangible (e.g. intellectual property), or even a bank account or accrued

interest. The law simply imposes an obligation to perform an act, the payment

of benefits.” Id.

[¶31] Here, there is no identifiable property right or interest at stake that

could form the basis of a takings claim. The statute and rules merely impose an
20

obligation to pay premiums into a fund that exists wholly separate from the

public fisc. Moreover, that an employer can substitute a private plan for the

PFML program does not create a corresponding property right in premiums

that have already been remitted to the fund, particularly when employers who

are not substituting a private plan must also remit premiums for the same

period.

[¶32] Accordingly, we answer questions II and III in the negative and

conclude that the Department’s rule requiring employers to pay nonrefundable

premiums into the fund does not result in a cognizable takings claim under

either the Maine or the U.S. Constitution.

The entry is:

Report accepted. We answer each of the three

questions presented in the negative. Remanded
to the Superior Court for further proceedings
consistent with this opinion.

Joshua D. Dunlap, Esq., Sara A. Murphy, Esq. (orally), and Katherine E. Cleary,
Esq., Pierce Atwood LLP, Portland, for appellants Maine State Chamber of
Commerce and Bath Iron Works Corporation

Aaron M. Frey, Attorney General, Nancy Macirowski, Asst. Atty. Gen. (orally),
and Anne Macri, Asst. Atty. Gen., Office of the Attorney General, Augusta, for
appellees Department of Labor and Laura A. Fortman
 21

Laura H. White, Esq., White & Quinlan, LLC, Kennebunk, for amici curiae A
Better Balance, National Partnership for Women & Families, and Maine
Employment Lawyers Association

Gerald F. Petruccelli, Esq., and Scott D. Dolan, Esq., Petruccelli, Martin &
Haddow, LLP, Portland, for amici curiae The Cianbro Companies, The Jackson
Laboratory, Maine Bankers Association, Maine Employers’ Mutual Insurance
Company, Maine Independent Colleges Association, Northern Light Health, and
The Sheridan Corporation

Kennebec County Superior Court docket number CV-2025-7

FOR CLERK REFERENCE ONLY