## Facts

- Daniel and Mona Gagnon owned a home in Van Buren, Maine, insured under a homeowner’s policy issued by Allstate Insurance Company.
- After returning from a weekend trip on May 29, 1989, they found extensive interior damage.
- The alleged cause was a rupture of the washing machine’s hot water hose during their absence, releasing hot water and steam.
- The policy excluded “water damage” but provided coverage for “direct loss caused by explosion.”
- The Gagnons claimed $10,964.04 in loss; Allstate denied coverage.
- In the District Court, the judge found the sudden release of water was an “explosion” within the policy, but concluded most loss resulted from subsequent water and steam flow and that the Gagnons failed to prove damages directly caused by the explosion; judgment entered for Allstate.
- On appeal, the Superior Court vacated the District Court judgment, ruled the explosion coverage applied, and remanded to the District Court to determine damages.
- Allstate appealed the Superior Court’s remand order to the Maine Supreme Judicial Court.

## Issues

1. Whether the Superior Court’s order vacating the District Court judgment and remanding for a determination of damages was a final judgment appealable to the Maine Supreme Judicial Court.

## Decision

- The Maine Supreme Judicial Court dismissed Allstate’s appeal for lack of appellate jurisdiction.
- The Court held the Superior Court’s order remanding for a damages determination was interlocutory and not a final judgment.
- The Court did not reach the merits of coverage, the water-damage exclusion, or proof of damages.

## Legal Principles

- Maine appellate review generally requires a final judgment; interlocutory orders are not appealable absent a recognized exception.
- A judgment is final only if it fully disposes of the whole matter, leaving nothing for further trial-court consideration, and no later proceedings can render an appellate decision immaterial.
- An order that vacates a judgment and remands for further proceedings, including determination of damages, ordinarily is not final and does not satisfy the final-judgment rule.

## Conclusion

Because the Superior Court’s remand left damages unresolved and required further District Court proceedings, the order was not final; the appeal was dismissed and the case proceeded in the trial court on remand for a damages determination.


Gagnon v. Allstate Ins. Co., 635 A.2d 1312 (Me. 1994)