Sears, Roebuck & Co. v. State Tax Assessor

[¶ 1] Sears, Roebuck & Company (Sears) appeals from the entry of a final judgment in the Business and Consumer Docket (Nivison, J.) concluding that, as a matter of law, our holding in Linnehan Leasing v. State Tax Assessor, 2006 ME 33, 898 A.2d 408, applies retroactively. Sears argues 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.1 Sears urges us to adopt the three-part test enumerated in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07, 92 S.Ct. 349, 30 L.Ed.2d…