Justia Maine Supreme Court Opinion Summaries

A developer sought approval from a municipal planning board to build a new residential subdivision, proposing two access roads: one through an existing neighboring subdivision and another via a road in a neighboring town. The developer’s plan designated the road through the existing subdivision as the main entrance and the other as an emergency access. During public hearings and board review, nearby residents and their homeowners’ association raised concerns about traffic safety, particularly for pedestrians and children, on the proposed main access road. After review and site visits, the planning board approved the subdivision but imposed a condition requiring that the road through the existing subdivision be limited to emergency access, making the other road the primary entrance.The developer challenged this condition in the York County Superior Court, arguing that the planning board lacked authority to impose such a restriction, that the decision was unsupported by evidence, and that it was arbitrary and capricious. The Superior Court initially remanded the matter for additional findings, after which the planning board reaffirmed its condition, citing pedestrian and bicycle safety concerns. The Superior Court ultimately denied the developer’s appeal, upholding the planning board’s decision.On further appeal, the Maine Supreme Judicial Court reviewed the planning board’s decision directly for errors of law, abuse of discretion, or lack of substantial evidence. The Court held that the planning board had authority under the municipal ordinance to impose conditions to ensure public safety, that the condition was supported by substantial evidence including resident testimony and board observations, and that the decision was not arbitrary or capricious. Accordingly, the Court affirmed the judgment of the Superior Court. View "Mick Land Development, Inc. v. Town of South Berwick" on Justia Law

Jesse Pelletier was charged with gross sexual assault and unlawful sexual contact after an incident at a party in March 2022. The victim alleged that while she was lying on a couch, Pelletier initiated unwanted sexual advances, despite her repeated objections and statements that she had a boyfriend and did not want to engage in sexual conduct. After the victim escaped and returned to search for her keys, Pelletier again attempted sexual contact, which she resisted. The charges required proof that the victim had not acquiesced to the sexual acts and that Pelletier was criminally negligent regarding whether she had acquiesced.The trial was held in the Hancock County Unified Criminal Docket before an Active Retired Justice. It was a jury-waived trial. Pelletier admitted that sexual acts occurred but claimed they were consensual. The trial court found, based on testimony from the victim and a mutual friend who overheard the victim objecting, that the victim had not acquiesced and that Pelletier was criminally negligent as to her acquiescence. Pelletier was convicted of gross sexual assault (Class C) and unlawful sexual contact (Class C), but found not guilty of two other, more serious charges because the court concluded the State had not proven compulsion beyond a reasonable doubt. Pelletier was sentenced to three years’ imprisonment, with part suspended, and two years of probation. He appealed the conviction.The Maine Supreme Judicial Court reviewed the evidentiary rulings for abuse of discretion and other claims for obvious error. It held that the friend’s testimony about what the victim said was not hearsay, as it was not offered for the truth of the statements but to show that the victim communicated her lack of acquiescence. The Court also held there was no error in admitting the testimony, finding it relevant and not unfairly prejudicial. The Court affirmed the judgment. View "State of Maine v. Pelletier" on Justia Law

This case involves a dispute over the management and succession of a living trust established by the stepfather of Mitchell D. Brown and Tina J. Bowden. Brown alleged that Bowden, while serving as trustee, breached fiduciary duties, amended the trust improperly to appoint Diahanne L. Morse as successor trustee, and engaged in self-dealing. After Bowden’s death, Morse acted as both the representative of Bowden’s estate and as the purported trustee. Brown sought damages, declaratory relief to void Morse’s appointment, and the naming of an independent trustee. Morse denied the allegations and brought counterclaims for tortious interference and slander of title related to trust property.The Waldo County Superior Court granted Brown’s motion to amend his complaint to add claims against Morse personally and for declaratory relief. Later, the court entered partial summary judgment for Brown, declaring that he was the properly nominated trustee and that the attempted amendment appointing Morse was void. Brown voluntarily dismissed several claims without prejudice, and the court denied Morse’s motion to dismiss for lack of subject-matter jurisdiction. The court then purported to enter “final judgment,” declaring the prior summary judgment to be final and dismissing remaining claims as moot, but did not address all outstanding claims.The Maine Supreme Judicial Court reviewed the case and determined that the Superior Court’s order was not a final judgment because it did not resolve all claims in the amended complaint or all of Morse’s counterclaims. The Court dismissed Morse’s appeal as interlocutory, finding that none of the recognized exceptions to the final judgment rule applied. The Court also denied Brown’s request for sanctions. The case will remain in the Superior Court until all claims are fully resolved. View "Brown v. Morse" on Justia Law

Leonard and Pauline Cortellino executed a promissory note and mortgage in 2006 for the purchase of property in Maine. The mortgage, originally granted to Mortgage Electronic Registration Systems (MERS) as nominee for Mortgage Lenders Network USA, Inc. (MLN), was later assigned multiple times, ultimately to Wilmington Savings Fund Society, FSB, as Trustee for Brougham Fund I Trust in 2016. However, MLN filed for bankruptcy in 2007 and ceased operations after the bankruptcy concluded in 2012. Due to deficiencies in prior assignments following the Maine Supreme Judicial Court’s decision in Bank of America, N.A. v. Greenleaf, parties sought to cure the assignment defects. In 2021, a receiver for MLN, appointed by the Delaware Court of Chancery, assigned the Cortellino mortgage to Wilmington Savings, which was recorded in 2022.After the Cortellinos defaulted on their mortgage payments in 2014, Wilmington Savings sent them a notice of default and right to cure in August 2022. Wilmington Savings filed a foreclosure action in the Maine Superior Court (Androscoggin County) in October 2022. Following a trial in October 2024 and post-trial submissions, the Superior Court entered a judgment of foreclosure and sale in April 2025. The court found Wilmington Savings owned the mortgage and denied the Cortellinos’ motion for additional findings. The Cortellinos appealed.The Maine Supreme Judicial Court reviewed the Superior Court’s factual findings for clear error and its legal conclusions de novo. The Court held that Wilmington Savings was the rightful owner of the mortgage due to the valid receiver’s assignment, but found that the right-to-cure notice was legally defective. The notice overstated the amount required to cure the default and contained numerical inconsistencies, failing to strictly comply with Maine’s statutory requirements. The Court vacated the judgment and remanded for entry of dismissal. View "Wilmington Savings Fund Society v. Cortellino" on Justia Law

In July 2020, the defendant was living with his girlfriend and their two-month-old child. One early morning, while the child was in his sole care, she became unresponsive. Emergency responders found the child not breathing and with no pulse, and she died four days later. Medical examinations revealed severe head and spinal injuries, including a skull fracture and hemorrhages, consistent with nonaccidental trauma. The defendant stated the child had choked while being burped and referenced a prior accidental fall. The prosecution presented expert testimony asserting the injuries were caused by abusive head trauma, while the defense argued they resulted from an earlier accident and subsequent choking.The case was tried in the Androscoggin County Unified Criminal Docket before a jury, which acquitted the defendant of murder but convicted him of manslaughter. The court sentenced him to twenty-three years, with all but eighteen years suspended and six years of probation. The defendant appealed, challenging evidentiary rulings under Rules 403 and 404(b), the sufficiency of the evidence, alleged prosecutorial error during closing argument, and the propriety of his sentence.The Maine Supreme Judicial Court reviewed the case. It held that the trial court did not abuse its discretion in admitting two autopsy photographs and body-worn camera footage, and found that objections to other photographs and certain injury evidence were waived. The evidence was sufficient to support the manslaughter conviction. Although the prosecutor erred by expressing a personal opinion on witness credibility, the error was harmless due to a curative instruction. The sentencing was upheld, as the court did not improperly consider the defendant’s decision to stand trial or err in its application of sentencing factors. The court affirmed the conviction and sentence. View "State of Maine v. Averill" on Justia Law

The Department of Health and Human Services sought to terminate a mother’s parental rights to five of her children, alleging unsafe living conditions and chronic truancy. The children were placed in the Department’s care after a preliminary protection order was issued. At the termination hearing, the Department presented evidence including four positive drug screens for the mother, with testimony from the director of her addiction treatment center and a forensic toxicologist. The mother objected to the admission of testimony regarding three of the drug tests, arguing they were hearsay and lacked proper foundation.The District Court in Newport held hearings on the Department’s petition, ultimately finding by clear and convincing evidence that the mother was unfit on two of the four statutory bases and that termination was in the children’s best interests. The court relied heavily on the four drug screens, referencing them repeatedly in explaining its decision. The mother appealed, challenging both the sufficiency of the evidence and the admission of the drug screens.The Maine Supreme Judicial Court reviewed the District Court’s decision, applying abuse of discretion and clear error standards for evidentiary rulings. The Court held that the admission of testimony regarding the June and July drug screens was improper hearsay, as the test results were not properly authenticated or admitted as exhibits, and the program director had no personal knowledge of the testing process. The Court concluded that the error in admitting this evidence was not harmless because the trial court’s decision was substantially based on the improperly admitted drug screens. Accordingly, the Maine Supreme Judicial Court vacated the judgment terminating the mother’s parental rights and remanded for further proceedings. View "In re Children of Jennifer B." on Justia Law

The appellant owned a condominium unit in Old Orchard Beach, Maine, subject to the Tidewater Loft Condominium Association’s declaration, which required payment of fees and assessments. After accruing tens of thousands of dollars in unpaid dues, expenses, and legal fees, she received notice of her right to cure the default, but did not do so. The Association initiated foreclosure proceedings. In response, the appellant filed a counterclaim, alleging violations of the Fair Housing Act and the Americans with Disabilities Act, based on the Association’s alleged failure to accommodate her daughter’s disability in connection with snow removal and trash disposal.The Biddeford District Court held a bench trial, at which the appellant appeared pro se. Although pretrial proceedings had identified her counterclaim as an issue for trial, the court ultimately limited the trial to the foreclosure issues and expressly excluded the counterclaim, preventing the appellant from presenting evidence or cross-examining on matters related to her claim. The court then entered judgment of foreclosure and sale for the Association and also entered judgment against the appellant on her counterclaim, concluding she had presented no persuasive evidence, despite not allowing her to do so.On appeal, the Maine Supreme Judicial Court reviewed the procedural due process claim de novo. The court held that the trial court’s failure to permit the appellant to present evidence or be heard on her counterclaim constituted a violation of her procedural due process rights. The Maine Supreme Judicial Court vacated both the foreclosure judgment and the judgment on the counterclaim, remanding for further proceedings to allow the appellant an opportunity to be heard on her counterclaim. View "Tidewater Loft Condominium Association v. Moskal-Kanz" on Justia Law

A Massachusetts resident was hired by a staffing company authorized to do business in Massachusetts and assigned to work for a New Hampshire corporation at a job site in Maine. The staffing company and the New Hampshire corporation had an agreement stating that the staffing company would provide employees, pay their wages and benefits, and handle workers’ compensation. The New Hampshire corporation supervised the employees on site. While working in Maine, the employee was injured. He filed a workers’ compensation claim in Massachusetts against the staffing company, which was settled.Subsequently, the employee filed a negligence lawsuit against the New Hampshire corporation in the Cumberland County Superior Court in Maine. The corporation moved for summary judgment, arguing that it was immune from suit under Maine’s Workers’ Compensation Act, specifically 39-A M.R.S. § 104, which provides immunity to employers using temporary help services under certain conditions. The Superior Court denied the motion, concluding that Massachusetts law governed the immunity issue, not Maine law, and that under Massachusetts law, the corporation was not immune. The corporation appealed.The Maine Supreme Judicial Court reviewed the denial of summary judgment, applying Maine’s choice of law rules. It determined that Massachusetts law governed the workers’ compensation immunity issue because Massachusetts had the most significant relationship to the parties and the occurrence. The Court further held that, under Massachusetts law, the New Hampshire corporation did not qualify for immunity because it was not contractually liable for workers’ compensation benefits to the injured employee. The Court affirmed the Superior Court’s denial of summary judgment, making clear that the corporation was not entitled to immunity from the employee’s negligence claim under the applicable law. View "Valmont-Oliver v. Envirovantage, Inc." on Justia Law

Carissa Daniels filed a complaint in August 2023 alleging that Patrick R. O’Brien committed timber trespass on her property by cutting trees and bushes. O’Brien’s homeowner’s insurer, MMG Insurance Co., initially defended him under a reservation of rights but later withdrew that reservation and settled the claim with Daniels. Daniels then moved to dismiss her complaint with prejudice as part of the settlement. O’Brien objected to both the settlement and the dismissal, arguing he should have the opportunity to defend against Daniels’s claim and thereby preserve a potential wrongful use of civil process claim against her.The Superior Court (Oxford County) held a hearing on the motions. During the hearing, MMG moved to intervene to support Daniels’s dismissal, while O’Brien moved to keep the matter on the court’s docket. The court granted Daniels’s motion to dismiss with prejudice in February 2025 and denied O’Brien’s motion for further findings of fact and conclusions of law. O’Brien then appealed, raising procedural objections and challenging MMG’s authority to settle over his objection.The Maine Supreme Judicial Court reviewed the case and found no abuse of discretion by the Superior Court in granting the dismissal with prejudice. The Court explained that under Maine Rule of Civil Procedure 41(a)(2), whether to allow a voluntary dismissal is within the trial court’s discretion and does not require a hearing unless evidence is taken. The Court further held that there was no procedural error, and that the merits of the settlement and MMG’s authority to settle were not at issue in this proceeding. The judgment of the Superior Court was affirmed. The main holding is that a trial court does not abuse its discretion by granting a plaintiff’s motion to dismiss with prejudice, even over a defendant’s objection based on potential future claims. View "Daniels v. O'Brien" on Justia Law

An individual, R., who had previously been placed under the guardianship of the Department of Health and Human Services due to multiple strokes and a diagnosis of moderate vascular dementia, petitioned to terminate his guardianship. R. resided in an assisted living facility, needed help with daily living activities, and demonstrated poor understanding of his own cognitive limitations. He was also expected to inherit a substantial sum, raising concerns about his susceptibility to financial exploitation. The Department sought to be appointed as his conservator, citing his impaired ability to manage his finances and personal affairs.The Cumberland County Probate Court consolidated R.’s petition to terminate the guardianship with the Department’s petition for conservatorship and held a hearing. After considering evidence, including testimony from medical providers and behavioral observations, the court denied R.’s request to terminate the guardianship and appointed the Department as his conservator, finding by clear and convincing evidence that R. remained incapacitated and in need of protection. R. appealed, arguing that the evidence did not support the Probate Court’s findings and that he received ineffective assistance of counsel because his attorney failed to obtain an independent psychological evaluation.The Maine Supreme Judicial Court affirmed the Probate Court’s judgment, holding that the evidence supported the denial of the petition to terminate guardianship and the grant of conservatorship. The court expressly recognized, for the first time, that individuals in guardianship or conservatorship proceedings have a right to the effective assistance of counsel, and adopted the Strickland v. Washington standard for evaluating such claims. The court articulated a procedure for raising ineffective assistance claims in these proceedings but found that R.’s claim lacked merit because he did not show that his counsel’s alleged deficiencies prejudiced the outcome. Judgment was affirmed. View "Adult Guardianship and Conservatorship of R." on Justia Law