A federal appeals court is reviving a woman’s lawsuit against a former Maine judge over sexual harassment allegations.

Former Bangor judge Charles Budd attends a hearing held by the Maine Board of Overseers of the Bar in October 2024. Screenshot from Maine Board of Overseers of the Bar hearing
Samantha Pike sued Charles Budd, who oversaw the Penobscot County drug treatment court, in U.S. District Court in Bangor in late 2022. She said Budd made several unwelcome sexual advances toward her at a work conference in Nashville that summer. Pike said she was frightened by the encounter and worried for her job as the court’s lead treatment provider.
Chief U.S. District Judge Lance Walker dismissed Pike’s complaint in June 2023, saying that she didn’t have standing to sue Budd and that there was no evidence the judge abused his authority to harass her. Walker also ruled that Budd was covered by “qualified immunity,” which shields public employees from being sued for actions performed in the course of their work.
But the 1st U.S. Circuit Court of Appeals in Boston ruled on Friday that Budd’s actions were not covered by qualified immunity because “a reasonable official in his position would have known that such conduct would violate” Pike’s right to be free from a hostile work environment.
In the order, the appeals court wrote that Pike’s complaint “sufficiently portrays a state-powered supervisor who crossed the line from merely making uncomfortable and inappropriate comments to one who engaged in sexual harassment.”
The justices did not rule on whether Pike proved that Budd was liable for harassment, agreeing only that Pike’s case should not have been dismissed and should proceed, potentially toward trial.
Pike’s allegations include one instance in which Budd followed her back to her hotel room and pressured her to invite him inside.
“We think that the intimidating nature of the event colors how a reasonable person could perceive the alleged inappropriate comments made by Budd described above,” the court wrote. “Additionally, it tends to establish a trend of potentially intimidating and, frankly, creepy behavior.”
Midcoast District Attorney Natasha Irving had also joined the lawsuit against Budd, saying he had harassed her at the same work conference. Irving, however, did not appeal the dismissal.
Budd referred questions about the latest ruling to his attorney, who did not immediately respond to an email Monday.
He previously argued that the case should be dismissed because the allegations against him didn’t describe illegal behavior. Budd said he wasn’t accused of making any physical advances or pressuring Pike for sexual favors, and he was not acting within the context of his obligations as a judge.
Pike’s attorney said Monday that they were pleased with the decision.
“Samantha Pike deserves to have her day in court,” her attorney, Laura White, wrote in an email. “She looks forward to finally holding Charles Budd accountable for his behavior.”
Budd is no longer a judge. He was placed on administrative leave in late 2022 and declined to seek reappointment when his term ran out in February 2023.
The Maine bar agreed to publicly admonish Budd last month for his conduct at the Nashville work conference after hearing testimony from Pike, Budd and several others who also attended the conference in Tennessee, but they stopped short of imposing any official discipline.
Comments are not available on this story.
about why we allow commenting on some stories and not on others.Send questions/comments to the editors.