Justia Maine Supreme Court Opinion Summaries

The case centers on a competitive bidding process conducted by the Maine Department of Health and Human Services (DHHS) for a contract to provide medical nonemergency transportation (NET) brokerage services in one of the state’s transit regions. Waldo Community Action Partners (Waldo CAP), the incumbent provider in Region 5 since 2014, submitted a proposal in response to the Request for Proposals (RFP). The RFP required bidders to detail their qualifications and provide three examples of relevant projects. Waldo CAP only completed details for one project, leaving the remaining two project sections blank except for the notation “NA.” After scoring, Waldo CAP did not receive the highest overall score; ModivCare Solutions, LLC, a vendor with extensive experience in other regions, was awarded the contract.Waldo CAP appealed the contract award to the Department of Administrative and Financial Services (DAFS) appeal committee, arguing that the process violated procurement laws and that the decision was arbitrary and capricious. The appeal committee affirmed DHHS’s decision, finding the point deduction for incomplete information justified and not arbitrary. Waldo CAP then sought judicial review in the Maine Superior Court, which also affirmed the committee’s decision.The Supreme Judicial Court of Maine reviewed the case, applying a deferential standard to the agency’s factual findings and statutory interpretations. The Court held that the “best-value bidder” under Maine law is determined strictly by the criteria and requirements set forth in the RFP, and that the agency acted within its discretion in scoring and did not act arbitrarily or capriciously. The Court affirmed the lower court’s judgment, upholding the award to ModivCare and lifting the stay on the contract award. View "Waldo Community Action Partners v. Department of Administrative and Financial Services" on Justia Law

The dispute centers on an injury suffered by Catherine Dudley at a property owned by Michel Kanyambo and Speciose Mahirwe, which was insured under a general liability policy issued by Hudson Specialty Insurance Company. The policy, procured through intermediaries, was in effect from September 14, 2017, to September 14, 2018. Before the expiration, a renewal quote was relayed from Hudson’s intermediary to Kanyambo via their insurance agent, but Kanyambo and Mahirwe never received a written quote nor communicated directly with Hudson or its intermediary. They took no steps to renew, and no written notice of nonrenewal was sent to them. Dudley was injured on the property nine days after the policy’s expiration and, after settling her claims against the owners, she initiated a statutory “reach-and-apply” action against Hudson.In the Androscoggin County Superior Court, both Dudley and Hudson sought summary judgment on whether the policy was effective at the time of the injury. The Superior Court granted summary judgment to Hudson, reasoning that the owners’ receipt of the renewal quote via their agent meant Hudson was not required to provide written notice of nonrenewal. The court found there was no material fact in dispute and held the policy was not in effect, barring Dudley’s claims against Hudson.The Maine Supreme Judicial Court reviewed the case de novo. It concluded that under the plain language of Maine’s statutes, an insurer must send a written notice of nonrenewal before a policy terminates at its expiration, regardless of whether the insurer offered to renew. The statutory definition of “nonrenewal” encompasses any termination at the expiration date, and failure to provide the required notice means the policy does not terminate. The Court vacated the summary judgment in favor of Hudson and remanded for further proceedings, holding that Hudson was obligated to send notice and its failure to do so meant coverage remained in effect. View "Dudley v. Hudson Specialty Insurance Company" on Justia Law

Eight residents of Boothbay and Boothbay Harbor challenged a school board’s refusal to put their petition for a new referendum before the voters. The underlying issue concerned a voter-approved bond to renovate local schools. After the bond passed, the residents submitted a petition containing two articles: one seeking to reconsider and repeal the prior vote, and another proposing a new, smaller bond for a different renovation project if the repeal succeeded. The school board rejected the petition, reasoning that it did not present a proper reconsideration question as required by statute and that the second article was unrelated to reconsidering the original referendum.The residents sought judicial review in the Lincoln County Superior Court under Rule 80B and also filed independent claims for a declaratory judgment and attorney fees, alleging a First Amendment violation. The Superior Court found that the petition was not a proper reconsideration petition because it included an additional article and that the independent claims were barred by the exclusivity principle. The residents then appealed.The Maine Supreme Judicial Court reviewed the case. It held that the statute governing reconsideration petitions imposes a ministerial duty on the board to initiate a referendum if the statutory requirements are met; thus, the Superior Court had jurisdiction. However, the Court found that the residents’ petition did not comply with the statutory requirements for a reconsideration petition, as it sought affirmative repeal and included a second, unrelated article, making it ineligible for submission to voters. The Court also affirmed the dismissal of the independent claims, holding there was no First Amendment violation. The judgment of the Superior Court was affirmed. View "Minerich v. Boothbay-Boothbay Harbor Community School District" on Justia Law

The case involves the conviction of a defendant for murder following the stabbing death of Kimberly Neptune, who was found in her apartment with 484 sharp force injuries. The defendant, Kailie Brackett, and a co-defendant, Donnell Dana, Jr., were indicted for intentional, knowing, or depraved indifference murder. The prosecution presented evidence including surveillance footage, testimony from witnesses about Brackett’s relationship with the victim and usage of the victim’s bank card, as well as forensic evidence from the crime scene. Notably, the prosecution relied on expert testimony comparing partial, sock-clad bloody footprints found at the scene to prints taken from Brackett in prison.The Washington County Unified Criminal Docket conducted the jury trial. Brackett objected to the admission of the forensic podiatry evidence, arguing it lacked scientific reliability. The trial court admitted the expert testimony over her objections, and the jury ultimately found Brackett guilty, but deadlocked as to Dana. Brackett was sentenced to fifty-five years in prison and appealed her conviction and sentence, challenging the sufficiency of the evidence, admission of the expert testimony, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court erred in admitting the forensic podiatry testimony comparing the partial, sock-clad footprints. The expert’s methodology lacked scientific reliability and was not sufficiently grounded in recognized standards, and the prosecutor’s closing arguments improperly characterized this evidence as definitive proof of Brackett’s presence at the scene. Because this error was likely to have affected the jury’s verdict, the Court vacated Brackett’s conviction and remanded for a new trial, holding that the State may retry Brackett but must exclude the challenged footprint comparison testimony. View "State of Maine v. Brackett" on Justia Law

Aaron Aldrich was convicted of two counts of intentional or knowing murder and possession of a firearm by a prohibited person. The evidence at trial showed that Aldrich went to a trailer in Poland, Maine, carrying a nine-millimeter rifle. He entered the trailer, shot both an adult and a teenager multiple times, and took a handgun and cash before leaving. Afterward, Aldrich told his friend he had killed the residents and instructed his girlfriend to dispose of evidence. The police later found forensic evidence linking Aldrich to the crime scene and recovered the murder weapon. He was apprehended in New Hampshire after fleeing in a stolen van.The Androscoggin County Unified Criminal Docket conducted a jury trial. Aldrich moved to suppress his post-arrest statements, claiming Miranda violations and improper questioning after requesting counsel; this motion was denied after an evidentiary hearing. The trial court made several evidentiary rulings, including admitting images of the victims, evidence of Aldrich’s theft and flight, testimony about his prior acts, and limiting cross-examination of witnesses. Aldrich testified, claiming self-defense. The jury found him guilty on all counts. He was sentenced to concurrent life terms for the murder convictions and five years for the firearm-possession count. Aldrich appealed both his convictions and sentences, arguing errors in suppression, evidentiary rulings, jury instructions, and sentencing analysis.The Maine Supreme Judicial Court reviewed all claims. The court held that the denial of the motion to suppress was correct because Aldrich was not subjected to custodial interrogation under Miranda. Most evidentiary rulings were proper; the few errors identified, including admission of hearsay and exclusion of certain defense evidence, were harmless and did not cumulatively deprive Aldrich of a fair trial. The jury instructions and sentencing analysis were found to be legally sound. The court affirmed the convictions and sentences. View "State of Maine v. Aldrich" on Justia Law

In 1996, a series of crimes including gross sexual assault and burglary were committed in Hancock County, Maine. The State filed a criminal complaint in August 2002, just before the statute of limitations was set to expire, naming the accused as “John Doe #1, Unknown Male with Matching Deoxyribonucleic Acid (DNA) Profile at 13 Genetic Locations.” An arrest warrant based on the DNA profile was issued. For the next twenty years, advancements in forensic genetic genealogy eventually enabled law enforcement to identify Jason J. Follette as the suspect. In November 2022, the State amended the complaint to specifically name Follette and charged him with the same offenses. Follette was arrested, appeared in court, and was released on bail.The case was reviewed by the Maine District Court in Hancock County. Follette filed several pretrial motions, including the motion to dismiss at issue here, arguing that (1) the State’s prosecution was barred because he was not specifically named in the initial complaint within the statute of limitations, and (2) the lengthy delay violated his Sixth Amendment right to a speedy trial. After a hearing, the court denied the motion, finding that the 2002 complaint tolled the statute of limitations and that his speedy trial rights were not violated.On appeal, the Maine Supreme Judicial Court considered Follette’s arguments but ultimately concluded that the appeal was interlocutory, as it sought review of a pretrial order denying a motion to dismiss. The court determined that none of the recognized exceptions to Maine’s final judgment rule applied, including the judicial economy, death knell, or collateral order exceptions. As a result, the court dismissed the appeal for lack of a final judgment, holding that review of the statute of limitations and speedy trial claims must await final resolution of the case. View "State of Maine v. Follette" on Justia Law

A solar energy developer sought to build a facility in Maine with an initial capacity of 4.98 megawatts, later reduced to 1.99 megawatts after changes to state law. The developer submitted an interconnection application to the local utility, obtained necessary permits, made payments, and began construction. During the project’s development, delays occurred in procuring key equipment, such as the meter and voltage regulator, resulting in a projected completion date after the statutory deadline of December 31, 2024. Despite the developer’s efforts, the facility was not operational by the required date.The developer petitioned the Maine Public Utilities Commission for a good cause exemption from the Commercial Operation Date deadline under Maine’s Net Energy Billing statute. After discovery and intervention by the Office of the Public Advocate, a Commission staff report recommended granting the exemption. However, the Commission ultimately denied the exemption, finding insufficient evidence that the developer ever received an initial construction schedule projecting completion within the 2024 deadline. The developer subsequently petitioned to reopen the record to submit additional evidence, but the Commission did not act on the petition within the required timeframe, resulting in a deemed denial. The developer appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court affirmed the Commission’s orders. The Court held that the Commission’s factual finding—that the developer failed to prove receipt of an initial schedule with a timely completion date—was supported by substantial evidence. The Court also found the Commission’s interpretation of the statute reasonable, its decision not arbitrary, and its refusal to reopen the record not an abuse of discretion. The judgment of the Commission was affirmed. View "Ellsworth ME Solar, LLC v. Public Utilities Comission" on Justia Law

Between 2019 and 2022, a bookkeeper for a family-owned machine and fabrication business misappropriated approximately $500,000 from her employer. She forged the co-owner’s signature on checks made out to herself and later confessed to the theft in a video-recorded interview with law enforcement. The bookkeeper admitted to taking funds for personal use and acknowledged the significant amount taken. She was charged with theft by unauthorized taking or transfer and forgery, pleaded not guilty, and proceeded to a jury trial.Prior to trial, the defendant sought access to the company’s QuickBooks password through a motion to compel discovery, which she later withdrew. She subsequently moved to suppress her confession as involuntary, but the Unified Criminal Docket (Piscataquis County, Roberts, J.) denied the motion after a hearing. Additional pretrial motions included a request for the trial judge’s recusal, based on his prior professional association with the prosecutor, and a motion to exclude financial evidence due to the State’s failure to produce the QuickBooks password. Both motions were denied. At trial, the prosecution presented testimonial, documentary, and video evidence, including the defendant’s confession. The jury found her guilty on both counts, and she was sentenced to concurrent prison terms, with part of the sentence suspended and probation imposed.On appeal, the Maine Supreme Judicial Court reviewed claims of prosecutorial error, denial of recusal, and alleged discovery violations. The Court held that although some prosecutorial statements constituted error, these were harmless in light of overwhelming evidence of guilt, including the defendant’s own confession. The Court also found no abuse of discretion in denying recusal or in rulings regarding discovery, concluding the State was not obligated to produce information it did not possess. The conviction was affirmed. View "State of Maine v. Moulton" on Justia Law

A student was enrolled in a respiratory therapy program at a community college from 2017 to 2022. During her final year, supervisors at several hospitals where she completed clinical rotations reported concerns about her clinical performance, including patient safety issues and unprofessional conduct. After a series of incidents, she was suspended and ultimately dismissed from the program for violating the student code of conduct, specifically for conduct that endangered patient safety. The student argued that her difficulties were due to academic deficiencies rather than misconduct and also claimed she experienced discrimination based on her race and national origin.After her initial dismissal, the student sought review in the Somerset County Superior Court, which found the administrative record insufficient and remanded the matter for a new hearing. The college’s disciplinary committee held a second hearing, reviewed evidence from both the student and the administration, and again upheld her dismissal, explicitly finding no evidence of discrimination or bias. The student then brought a three-count action in the Superior Court: (1) an administrative appeal of her dismissal under Rule 80B, (2) a claim under 42 U.S.C. § 1983 for violation of procedural due process, and (3) a claim of unlawful educational discrimination under Maine law.The Maine Supreme Judicial Court held that the college’s decision to dismiss the student was not arbitrary or capricious and that the disciplinary process afforded her meaningful notice and an opportunity to be heard. The Court affirmed dismissal of the § 1983 and discrimination claims as duplicative of the administrative appeal, finding that her grievances were properly addressed through Rule 80B review, and that there was no evidence of discrimination or due process violations. The judgment of the Superior Court was affirmed. View "Hogan v. Kennebec Valley Community College" on Justia Law

Daniel Gantnier was convicted by a jury in 2006 of unlawful sexual contact, a sex offense that, under Maine law at the time, required lifetime registration as a sex offender. However, when the court imposed his sentence in 2007, the judgment and commitment form mistakenly indicated that he was obligated to register for only ten years instead of life. After Gantnier completed the ten-year term, the State Bureau of Identification reviewed his case, identified the error, and in 2019 notified him that his registration requirement was corrected to require lifetime registration. Gantnier did not comply with this requirement, and in 2022 the State charged him with failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999).Following his not guilty plea, Gantnier moved to dismiss the complaint in the trial court (Kennebec County), arguing that retroactively imposing a lifetime registration requirement violated the Ex Post Facto Clause of the United States Constitution and that the State’s correction should have been pursued under Rule 35(a), which governs correction of illegal sentences. The trial court (Daniel Mitchell, J.) denied his motion, finding that, due to a 2004 legislative amendment, SORNA of 1999 registration was not part of a criminal sentence for offenses like Gantnier’s. The court found that the correction was regulatory, not punitive, and thus not subject to ex post facto protections. After his motion for reconsideration was also denied, Gantnier entered a conditional guilty plea, reserving his right to appeal.On appeal, the Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that because Gantnier’s registration requirement was not part of his sentence, the retroactive correction to lifetime registration did not violate the Ex Post Facto Clause. The Court also determined that the State acted properly under 34-A M.R.S. § 11222(1), and was not required to proceed under Rule 35(a). The judgment was affirmed. View "State of Maine v. Gantnier" on Justia Law