Sears, Roebuck & Company v. State Tax Assessor

Sears, Roebuck & Company appealed a judgment which concluded as a matter of law that the Supreme Court's holding in "Linnehan Leasing v. State Tax Assessor," (898 A.2d 408) applied retroactively. Sears argued that Maine recognizes the practice of retroactively applying certain legal holdings of a decision in a case to the parties in that case but only prospectively in all other instances. Sears urged the Supreme Court to adopt the three-part test enumerated in "Chevron Oil Co. v. Huson" (404 U.S. 97, 106-07 (1971)) when deciding whether to apply the holding of a decision retroactively to other cases. Sears further argued that "Linnehan Leasing" should not apply retroactively because the three Chevron factors weigh in favor of applying the holding with selective prospectivity. Finally, Sears argued that the Court should have reaffirmed its holding in "Myrick v. James" (444 A.2d 987, 1001-02 (Me. 1982)). Without addressing the issue of retroactivity, the Court applied the plain meaning of the statute at issue and affirmed. View "Sears, Roebuck & Company v. State Tax Assessor" on Justia Law