Justia Maine Supreme Court Opinion Summaries

Fair Friend Enterprise Co., Ltd., a Taiwan-based company and majority shareholder of CNC Systems, Inc., sought access to CNC's corporate books and records under Maine law. Fair Friend alleged that CNC had failed to pay for goods worth approximately $4 million and had unilaterally demoted its CEO without approval. Fair Friend made a written demand for access to CNC's records, which CNC ignored, leading Fair Friend to file a complaint in the Maine Superior Court.The Maine Superior Court ordered CNC to produce the requested records and denied CNC's motion to stay the proceedings due to related litigation in California. The court found that Fair Friend had a proper purpose for requesting the records and that CNC's actions warranted concern. CNC continued to delay compliance, prompting further court orders to enforce the production of records and awarding attorney fees to Fair Friend.The Maine Supreme Judicial Court reviewed the case. CNC's appeal of the denial of the motion to stay was dismissed as moot because CNC eventually produced the requested records. The court affirmed the award of attorney fees, concluding that CNC had not acted in good faith and had no reasonable basis for doubting Fair Friend's right to inspect the records. The court found that CNC's resistance to producing the documents and filing of serial motions to delay justified the award of attorney fees. The case was remanded for dismissal of all pending motions and entry of final judgment. View "Fair Friend Enterprise Co., Ltd. v. CNC Systems, Inc." on Justia Law

An inmate at the Hancock County Jail, Monica J. Johnson, died by suicide after being incarcerated from September 21 to September 29, 2018. Her estate and surviving spouse filed a medical malpractice notice of claim against Hancock County and several county officials and employees, alleging negligence in her care. The County and its employees, along with Jail Housing Officer Kayla Dumond, appealed the Superior Court's denial of their motions for summary judgment.The Superior Court (Penobscot County) denied the motions for summary judgment, determining that it lacked jurisdiction to decide whether the Maine Health Security Act (MHSA) applied to the defendants and that the defendants had not demonstrated immunity under the Maine Tort Claims Act (MTCA). The Maine Supreme Judicial Court reviewed the interlocutory appeal.The court concluded that the issue of whether the defendants are "health care providers" under the MHSA is not immediately appealable. Additionally, the court decided to defer to the federal court on the issue of immunity under the MTCA, as the federal court is handling a related case involving the same parties and facts. Consequently, the appeal was dismissed, allowing the MHSA screening process to proceed, with the understanding that the federal court will continue with the litigation once the screening process is completed. View "Carney v. Hancock County" on Justia Law

Kingfish Maine, Inc. sought permits from the Department of Environmental Protection to construct and operate a land-based aquaculture facility in Jonesport, Maine. The project included two primary buildings, access roads, ancillary buildings, and intake and outfall pipes for water from Chandler Bay. The Department issued a wastewater discharge permit and a combined Site Law and Natural Resources Protection Act (NRPA) permit for the project.The Superior Court (Kennebec County) affirmed the Board of Environmental Protection’s decision to uphold the Department’s issuance of the permits. Petitioners, Eastern Maine Conservation Initiative and Roque Island Gardner Homestead Corporation, argued that the Board erred in its scope of review under NRPA and failed to independently evaluate the environmental impacts of the wastewater discharge.The Maine Supreme Judicial Court reviewed the case and held that the Board did not err in its interpretation of NRPA’s scope. The Court found that NRPA’s review is limited to specific activities listed in 38 M.R.S. § 480-C(2), which do not include the discharge of treated wastewater. The Court also held that the Board did not abuse its discretion by relying on the previously issued discharge permit, as the Department had already evaluated the environmental impacts of the discharge, including its effects on wildlife and water quality, during the discharge permit process.The Court affirmed the judgment of the Superior Court, concluding that the Board’s reliance on the discharge permit was reasonable and that the Board was not required to conduct a separate analysis of the wastewater discharge’s impact under NRPA. View "Eastern Maine Conservation Initiative v. Board of Environmental Protection" on Justia Law

Clifton Thomas was convicted of two counts of aggravated trafficking of scheduled drugs and one count of criminal forfeiture of property. The charges stemmed from a search of an apartment where Thomas was staying, which uncovered drugs, drug paraphernalia, and a firearm. The search was conducted pursuant to a warrant obtained after Thomas was involved in a domestic violence incident. Thomas challenged the search, arguing that the warrant lacked probable cause for drug-related items and that the evidence was not in plain view.The trial court denied Thomas's motions to suppress the evidence, finding that the search warrant was valid for firearms and a cell phone, and that the drugs were discovered in plain view during a lawful search. The court also denied Thomas's discovery motions regarding missing surveillance video, cell phones, and a coat, concluding that the State did not act in bad faith and that the evidence did not have apparent exculpatory value. Additionally, the court allowed a new chemist to testify about the drug analysis, despite the original chemist not testifying.The Maine Supreme Judicial Court reviewed the case and found that Thomas's confrontation rights were violated by the admission of the new chemist's testimony, which relied on the original chemist's notes and data. The court determined that this violation was not harmless, as the chemist's testimony was crucial to establishing the weight of the drugs, a key element of the charges. Consequently, the court vacated Thomas's conviction and remanded the case for further proceedings. View "State of Maine v. Thomas" on Justia Law

Pat Doe and Jarrod Burnham each filed complaints for protection from abuse against each other in December 2021. Doe's complaint was transferred to Portland for a consolidated hearing, where the court found that Burnham had abused Doe and granted her a two-year protection order effective until January 14, 2024. On January 4, 2024, Doe attempted to file a motion to extend the protection order in Bangor but was informed it needed to be filed in Portland. She mailed the motion on January 13, 2024, but it never arrived due to insufficient postage. Doe learned the order had not been extended on January 17, 2024, and filed a new protection from abuse action in Bangor.The District Court in Portland denied Doe's motion to extend the protection order, concluding it could not extend an expired order. Doe's motion for reconsideration was also denied, with the court finding that her failure to file on time was not excusable neglect and that the statute did not permit extending an expired order. Doe then filed a motion for relief from judgment, arguing excusable neglect, which was also denied. The court stated that excusable neglect under M.R. Civ. P. 60(b)(1) did not apply to statutory deadlines.The Maine Supreme Judicial Court affirmed the lower court's decisions, holding that 19-A M.R.S. § 4111(1) unambiguously prohibits extending an expired protection order. The court also held that a motion for relief from judgment cannot be used to circumvent statutory authority, and thus the trial court did not err in denying Doe's motion for relief from judgment. View "Doe v. Burnham" on Justia Law

Craig A. Woodard was convicted of elevated aggravated assault, aggravated assault, and assault after a jury trial. The trial court found that the offense of elevated aggravated assault was committed with the use of a firearm and imposed a mandatory minimum sentence of four years’ imprisonment. The court merged the offenses and sentenced Woodard to twelve years’ imprisonment with all but five years suspended and three years of probation. Woodard appealed, arguing that the court erred in failing to give jury instructions regarding defense of another and in applying the mandatory minimum sentence for a Class A offense committed with a firearm. He also contended that the court improperly considered his age and lack of remorse as aggravating factors.The trial court (Hancock County, Larson, J.) denied Woodard’s motion for a judgment of acquittal and sentenced him as described. Woodard’s appeal was consolidated with his sentence review appeal, which was granted by the Sentence Review Panel.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s judgment and sentence. The court held that Woodard waived the issue of jury instructions regarding defense of another by not requesting them at trial and agreeing with his counsel’s strategy. The court also found that the indictment sufficiently alleged the use of a firearm, justifying the mandatory minimum sentence. Additionally, the court ruled that considering Woodard’s age and lack of remorse as aggravating factors was within the trial court’s discretion and did not constitute an abuse of discretion. View "State of Maine v. Woodard" on Justia Law

Michaela Boland filed for divorce in October 2019. In September 2022, the parties reached a settlement agreement regarding the economic issues of their divorce, which was accepted by the court. The agreement included a provision for Nicholas Belair to transfer $50,000 annually to Michaela for five years, secured by a promissory note from Nicholas's father, Roland Belair. However, Roland later reneged on his commitment to fund the payments, leading Michaela to file a motion to enforce the settlement agreement.The District Court (Tice, J.) denied Michaela's motion to enforce the settlement agreement, finding that the agreement was based on a material mistake of fact and was therefore unenforceable. The court concluded that Nicholas could not make the payments without his father's assistance and set the matter for trial. Michaela appealed, but the appeal was dismissed as interlocutory. The court (D. Driscoll, J.) later held a bench trial and determined that Nicholas's interest in a real estate company was nonmarital property, leading to a final divorce judgment.The Maine Supreme Judicial Court reviewed the case and held that the settlement agreement was enforceable. The court found that all requirements for a binding settlement agreement were met, as the parties had reported the agreement to the court, read its terms into the record, and expressed clear consent. The court concluded that there was no mistake of fact at the time the agreement was reached, as Roland had agreed to fund the payments. The court vacated the order denying Michaela's motion to enforce, vacated the divorce judgment, and remanded for incorporation of the settlement agreement into a divorce judgment. View "Boland v. Belair" on Justia Law

Abdihamit A. Ali was convicted of elevated aggravated assault, reckless conduct with a dangerous weapon, possession of a firearm by a prohibited person, and criminal mischief following a jury trial in the Cumberland County Unified Criminal Docket. The court sentenced him to fifteen years, with all but seven years suspended, and four years of probation for the elevated aggravated assault charge, with concurrent sentences for the other charges. Ali appealed, arguing that the trial court improperly admitted hearsay testimony and failed to merge his convictions for elevated aggravated assault and reckless conduct with a dangerous weapon.The trial court admitted testimony from a detective about statements made by Ali’s mother to other officers, which Ali argued was hearsay. The court overruled Ali’s objection, and the jury found him guilty on three counts, while the court found him guilty on the fourth count. Ali was sentenced accordingly and appealed the decision.The Maine Supreme Judicial Court reviewed the case and agreed that the hearsay testimony should not have been admitted without a limiting instruction. However, the court found this error to be harmless given the substantial evidence against Ali. The court also agreed with Ali that his convictions for elevated aggravated assault and reckless conduct with a dangerous weapon should have been merged, as they did not each require proof of an additional fact and could have been based on the same conduct. Consequently, the court vacated the sentence and remanded the case for resentencing, merging the two convictions. The judgment was affirmed in all other respects. View "State of Maine v. Ali" on Justia Law

Christopher Ray was observed by a Cumberland Police Department officer riding his bicycle slightly to the left of the white fog line on Tuttle Road. The officer, traveling behind Ray and another cyclist, instructed them to ride single file. Ray responded with an expletive, prompting the officer to stop them and issue Ray a violation summons for failing to keep to the right of the road, as required by 29-A M.R.S. § 2063(2).Ray contested the violation, and a bench trial was held in the District Court (Portland). The court found Ray had committed the traffic infraction of not operating his bicycle on the right portion of the way as far as practicable and imposed a fine of $151. Ray appealed the decision to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the case de novo, focusing on the interpretation of 29-A M.R.S. § 2063(2). The Court found the statute ambiguous regarding where cyclists must operate when the command to ride to the right applies. The Court noted that the terms "roadway" and "way" were not clearly defined, and the statute's language left it up to the cyclist to determine what was safe, making enforcement difficult. The Court concluded that the ambiguity must be resolved in favor of Ray, vacated the adjudication, and remanded the case for entry of judgment in favor of Ray. View "State of Maine v. Ray" on Justia Law

Yolanda M. Currier and James M. Currier were married in 2000, and Yolanda filed for divorce in 2017. The divorce judgment, entered in 2019, awarded Yolanda sole parental rights and responsibilities for their three children, child support, spousal support, and half the value of James’s employee stock plan and 401(k) account. James was found to have committed economic misconduct by cashing in stocks and taking loans against his 401(k) during the divorce proceedings.The District Court (South Paris) found James in contempt multiple times for failing to comply with the divorce judgment. In 2023, Yolanda filed a fifth motion for contempt, asserting that James failed to provide an accounting of his stocks and did not file a proposed qualified domestic relations order (QDRO) for the division of his 401(k) account. The court found James not in contempt regarding the stock division, concluding that Yolanda did not prove James owned stocks. However, the court found James in contempt regarding the 401(k) account, valuing it at $7,000 and awarding Yolanda $3,500.The Maine Supreme Judicial Court reviewed the case and found that the District Court erred in its findings. The Supreme Judicial Court concluded that Yolanda met her burden of proving James’s noncompliance with the stock accounting and division order. The court also found that the District Court erred in valuing the 401(k) account at $7,000, as this figure excluded the value of loans taken against the account, contrary to the divorce judgment’s provisions.The Maine Supreme Judicial Court vacated the District Court’s judgment and remanded the case for further proceedings consistent with its opinion, noting James’s pattern of noncompliance and suggesting the consideration of punitive sanctions if his contumacious conduct continues. View "Currier v. Currier" on Justia Law