This decision from the Maine Supreme Judicial Court concerns an appeal by U.S. Bank National Association. The Bank sought an equitable lien on Charles Adams’s portion of a jointly owned property in Dedham, Maine, arguing that Charles benefited from his sister Dorothy’s use of a loan (secured by a mortgage on her interest in the property) to pay off an earlier joint debt.

The key points are:

• Background: In 2004, Charles conveyed part of his Dedham parcel to himself and his sister, Dorothy, as joint tenants. In 2005, Dorothy took out a $2.3 million loan from American Brokers Conduit (ABC), secured by a mortgage on her interest. Charles was present at the closing but explicitly refused to sign or be bound by the note and mortgage. Dorothy defaulted in early 2008.
• Lawsuit and Lower Court Decision: U.S. Bank (claiming standing through assignments) filed a complaint against Charles in May 2012, seeking an equitable lien based on an unjust enrichment claim, asserting Charles benefited from the loan proceeds. Charles argued the action was time-barred by the statute of limitations. The Superior Court ruled in Charles’s favor, denying the equitable lien on the merits.
• Appellate Court’s Decision: The Maine Supreme Judicial Court vacated the Superior Court’s judgment. It concluded that the U.S. Bank’s unjust enrichment claim, which formed the basis for the equitable lien, accrued in December 2005 (when Dorothy signed the note and mortgage). Since the complaint was not filed until May 2012, more than six years later, the claim was barred by Maine’s six-year statute of limitations for civil actions (14 M.R.S. § 752). The Court rejected U.S. Bank’s arguments that longer statutes of limitations related to notes and mortgages applied, as the claim was against Charles’s ownership interest, not an action to enforce the contested note itself.
• Outcome: The case was remanded for entry of dismissal due to the statute of limitations.

Summary by Gemini