The Maine Supreme Judicial Court ruled that insurance companies must send nonrenewal notices to policyholders even when offering to renew policies, reversing a lower court decision that had favored Hudson Specialty Insurance Company.
In *Catherine Dudley v. Hudson Specialty Insurance Company et al.*, decided Feb. 10, 2026, the court held that Maine statute 24-A M.R.S. § 2009-A(1) requires insurers to provide nonrenewal notices regardless of whether they simultaneously make renewal offers. The decision overturns a summary judgment ruling from Androscoggin County Superior Court.
Justice Lipez, writing for the unanimous court, stated that the lower court's conclusion was "contrary to the plain language of the applicable statutes." The case arose from a reach-and-apply action filed by Catherine Dudley after she was injured at a property insured by Hudson and owned by Michel Kanyambo and Speciose Mahirwe.
The insurance dispute centers on a general liability policy Hudson issued to Kanyambo and Mahirwe in 2017, covering their property from Sept. 14, 2017, to Sept. 14, 2018. The policyholders did not negotiate directly with Hudson but instead retained Champoux Insurance Group, which partnered with New England Excess Exchange Limited to procure the policy.
On July 31, 2018, a New England Excess employee emailed a Champoux employee a "renewal quote" for the policy. The Champoux employee then called Kanyambo to inform him of the quote, though the record shows the parties never finalized the renewal terms.
The legal dispute emerged when Dudley, who was injured at the insured property, filed a reach-and-apply action under Maine's insurance statutes. These actions allow injured parties to pursue claims directly against insurance companies when property owners fail to maintain adequate coverage or comply with policy requirements.
Superior Court Judge Archer originally ruled in Hudson's favor, finding that the insurance company was not required to send formal nonrenewal notices because it had made a renewal offer. The trial court interpreted Maine's insurance notification requirements as not applying when insurers actively pursue policy renewals.
The Maine Supreme Judicial Court disagreed with this interpretation. The appellate panel, which included Chief Justice Stanfill and Justices Mead, Connors, Lawrence, Douglas, and Lipez, found that the statutory language creates a mandatory duty for insurers to provide nonrenewal notices regardless of renewal negotiations.
Maine statute 24-A M.R.S. § 2009-A(1) establishes specific notice requirements for insurance companies when policies approach expiration. The Supreme Judicial Court's interpretation means that even when insurers actively negotiate renewals with policyholders, they must still comply with formal notification procedures.
This ruling could have significant implications for insurance practices throughout Maine. Insurance companies operating in the state will need to ensure their renewal processes include proper nonrenewal notices, even when they intend to continue coverage. The decision clarifies that renewal negotiations and statutory notice requirements operate as separate legal obligations.
The court's emphasis on "plain language" interpretation suggests that Maine courts will strictly enforce insurance notification statutes as written, rather than allowing companies to argue that practical circumstances excuse compliance. This approach aligns with Maine's general tendency to interpret insurance laws in favor of consumer protection.
For insurance companies, the ruling means additional administrative requirements during renewal periods. Companies must now ensure that formal nonrenewal notices accompany any renewal negotiations, potentially increasing paperwork and compliance costs. However, the decision provides clarity on statutory interpretation that should help insurers avoid future litigation.
The decision also affects injured parties who pursue reach-and-apply actions. When insurance coverage disputes arise due to improper notice procedures, injured claimants may have stronger grounds to challenge insurance companies' compliance with Maine law.
Legal practitioners representing both insurers and policyholders will need to review their clients' notice procedures in light of this ruling. The decision establishes clear precedent that renewal offers do not substitute for statutorily required nonrenewal notices under Maine insurance law.
The Supreme Judicial Court vacated the summary judgment and remanded the case for further proceedings, meaning the underlying dispute between Dudley and Hudson will continue in the trial court. The remand suggests that factual issues remain to be resolved regarding the specific circumstances of Hudson's policy renewal communications.
This decision joins a growing body of Maine insurance law that emphasizes strict compliance with consumer protection statutes. The court's unanimous ruling sends a clear message to insurers about the importance of following statutory procedures regardless of business practices or industry customs.
The case was argued Nov. 12, 2025, and decided Feb. 10, 2026, with the opinion issued as 2026 ME 12. The relatively quick turnaround from argument to decision suggests the court viewed the legal issues as straightforward once properly analyzed under Maine's statutory framework.