Justia Maine Supreme Court Opinion Summaries

Throughout the spring and summer of 2023, the defendant operated a large-scale drug trafficking operation from a residence he shared with three others. He communicated regularly with customers and directed his housemates to assist in drug transactions. Law enforcement, with the help of a confidential informant, orchestrated controlled purchases on three occasions. Each time, the informant arranged the purchase with the defendant by phone but acquired the drugs from someone else at the residence. The State later filed charges including multiple counts of aggravated drug trafficking and violating a condition of release.The case proceeded to a jury trial in the Waldo County Unified Criminal Docket. Before trial, the defendant stipulated to his prior felony drug trafficking convictions and pleaded guilty to violating a condition of release. The jury was instructed on both principal and accomplice liability, over the defense’s objection, and received both oral and written instructions. The jury ultimately convicted the defendant on two counts of aggravated drug trafficking—one for a specific date and one for a period covering several months—but acquitted him on one count and deadlocked on two others. The trial court merged the trafficking counts for sentencing, found ongoing criminal conduct, and imposed a thirty-year sentence.On appeal, the defendant argued to the Maine Supreme Judicial Court that the trial court erred in its instructions on accomplice liability and in the determination of his basic sentence. The Court held that, while the instructions included minor imperfections, when viewed as a whole they correctly and fairly informed the jury of the law. It also found the trial court’s sentencing analysis to be lawful and appropriate, as it was based on the nature and seriousness of the ongoing offense for which the defendant was convicted. The judgment of conviction and sentence were affirmed. View "State of Maine v. James" on Justia Law

A mother, Cassie S., was subject to a child protection proceeding after concerns were raised about her medical decision-making for her child, who had a complex medical history. Despite multiple recommendations from medical providers to remove the child’s tracheostomy and gastrostomy tube, the mother insisted on maintaining these interventions and sought further procedures. After a New York hospital visit revealed no medical basis for these interventions and the mother refused to allow further evaluation, the hospital reported suspected medical abuse to Maine’s Department of Health and Human Services, which then petitioned for a child protection order.The District Court in Portland initially struggled to serve the mother and obtain necessary medical records, in part because of the mother’s resistance. The court denied her request for appointed counsel after finding she was not indigent, but she eventually retained private counsel for the hearing. The court granted a continuance of the jeopardy hearing beyond the statutory 120-day deadline due to delays attributed to the mother and the complexity of the case. Following a hearing, the court found the child was in jeopardy, placed the child in the Department’s custody, and required steps toward demedicalization and psychological evaluation for the mother. The court also issued a broad order restricting the mother from discussing the case publicly. The mother’s motion for relief from judgment based on alleged ineffective assistance of counsel was denied without a hearing.The Maine Supreme Judicial Court affirmed the finding of jeopardy and the denial of the mother’s Rule 60(b) motion, holding that she was not entitled to appointed counsel, the continuance was justified for good cause, there was no error requiring recusal, and any negative inference regarding missing witnesses was harmless. The Court vacated the speech restriction order as overly broad and remanded for it to be narrowed and time-limited. View "In re Child of Cassie S." on Justia Law

A man was arrested in November 2022 after a Burger King manager reported to 9-1-1 that he saw the man with an open alcoholic beverage container in his vehicle and believed he had been drinking and driving. Police responded, blocked the man's vehicle from leaving the parking lot, and saw an open can of alcohol. Both the man and his passenger provided false names, and the driver ultimately admitted his real identity after being informed he was under arrest. A search incident to arrest yielded methamphetamine, fentanyl, drug paraphernalia, and cash on his person and in his vehicle.The Penobscot County Unified Criminal Docket initially granted the defendant's motion to suppress, concluding the stop was not supported by reasonable suspicion because the vehicle was not on a public way. The State moved for further findings and reconsideration, arguing that the parking lot was only accessible from a public way and that the officers reasonably believed a violation had occurred or was imminent. Upon reconsideration, the court added findings about the lot's access, denied the motion to suppress, and concluded the stop and subsequent searches were lawful. The court also denied suppression based on Miranda grounds and found the cash subject to forfeiture as drug proceeds or intended for drug trafficking.Reviewing the case, the Maine Supreme Judicial Court affirmed. The court held that the trial court did not err or abuse its discretion in reconsidering its suppression ruling. It found that the stop was supported by reasonable articulable suspicion, the searches and seizure of evidence were lawful, and the forfeiture of the cash was supported by sufficient evidence and did not violate the Eighth Amendment. The judgment was affirmed. View "State of Maine v. Martin" on Justia Law

Sean Eori was charged with multiple offenses, including unlawful sexual contact and possession of sexually explicit material, based on allegations that, between 2019 and 2022, he engaged in inappropriate conduct with a minor who was between twelve and fifteen years old. The minor was the child of Eori’s friend, and their relationship involved frequent communication and meetings. The evidence at trial included text and Instagram messages, physical gifts, and photographs, some of which depicted the minor nude or partially clothed, and some of which the minor sent to Eori at his request.After his arrest and indictment, Eori challenged several pretrial rulings in the Kennebec County Unified Criminal Docket. The court granted the State’s motion for a protective order, limiting Eori’s access to a Child Advocacy Center interview with the victim, so that he could only review it under his counsel’s supervision. The court also denied Eori’s motion in limine to exclude certain photographs, reasoning that whether the images were sexually explicit was a question for the jury. At trial, the court overruled Eori’s objections to the admission of these photographs, and after the State’s case, denied his motion for judgment of acquittal. Ultimately, the jury convicted Eori of unlawful sexual contact and two counts of possession of sexually explicit material, and he was sentenced to 180 days in jail.The Supreme Judicial Court of Maine reviewed the conviction. It held that the protective order was appropriate under state law, which mandates confidentiality for such interviews. The court found no error in admitting the photographs, concluding they were relevant and their probative value was not outweighed by unfair prejudice. The court further held that, under a totality of the circumstances approach, the jury could reasonably find the images met the statutory definition of “sexually explicit material.” The conviction was affirmed. View "State of Maine v. Eori" on Justia Law

A police officer in Lincoln, Maine, observed a vehicle that appeared to be speeding and conducted a traffic stop. The driver, Kenneth Rhoades, was uncooperative and displayed signs of impairment, including slurred speech and the odor of alcohol. During the encounter, Rhoades initially denied drinking but eventually admitted to consuming two alcoholic beverages. After Rhoades behaved aggressively toward the officer, he was transported to the police station, where he ultimately submitted to a breath test that showed a blood alcohol concentration of .16 grams per 210 liters of breath.Following the incident, the State charged Rhoades with operating under the influence with two prior OUI offenses within ten years. Rhoades filed a motion to suppress the evidence, arguing that the officer lacked reasonable articulable suspicion to justify the stop. The trial court (A. Murray, J.) denied the motion. Before trial, Rhoades also sought discovery sanctions due to the State’s delayed disclosure of impeachment information regarding a potential witness. The trial court (Roberts, J.) declined to impose sanctions after finding no prejudice to Rhoades, as the witness in question did not testify at trial. At trial, Rhoades objected to the admission of his breath test results, arguing insufficient foundational reliability and a Confrontation Clause violation. The trial court admitted the results.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The court held that the officer’s visual estimation of Rhoades’s speed, given the officer’s training and experience, provided reasonable articulable suspicion for the stop. The court also held that the breath test results were properly admitted, as the State established their reliability through expert testimony, and the admission did not violate the Confrontation Clause since the breath test was machine-generated data. Finally, the court found no abuse of discretion in denying discovery sanctions due to a lack of prejudice. View "State of Maine v. Rhoades" on Justia Law

Two applicants submitted materials to operate medical cannabis cultivation facilities in a Maine town in August 2024. Their initial applications did not include necessary documentation showing that their facilities would be located in a “Registered Cannabis Property,” which was required by the town’s licensing ordinance. Town staff reviewed the applications and placed them on the council agenda for a “first reading,” a step not required by ordinance but adopted by custom. On September 4, 2024, before the first reading of the applications, the Town Council amended the zoning ordinance to add a 1,000-foot setback requirement between cannabis facilities and residential properties—a standard the applicants’ locations could not meet. After the amendment, staff told the council the applications were “complete,” and the first reading occurred. The public hearing and further review were scheduled, and the required property registration was later filed. The council ultimately denied the applications for failing to meet the new setback requirement.The applicants sought judicial review in the Cumberland County Superior Court under Maine Rule of Civil Procedure 80B. The Superior Court affirmed the Town Council’s decision, concluding that the applications were not “pending” at the time of the ordinance amendment and thus were subject to the new setback requirement.On further appeal, the Maine Supreme Judicial Court reviewed whether the applications were “pending” within the meaning of 1 M.R.S. § 302 at the time the ordinance was amended. The court held that an application is not “pending” until the reviewing authority has conducted a substantive review of whether it meets the approval criteria. Because the Town Council had not begun substantive review before the zoning amendment was enacted, the applications were not pending and were properly denied under the amended ordinance. The judgment was affirmed. View "Shark Tank Strategies, LLC v. Town of Scarborough" on Justia Law

H.A.T., LLC entered into a bond-for-deed contract with Greenleaf Apartments, LLC to purchase three buildings in Portland for $1 million, with a down payment and monthly installments. H.A.T. took possession but would not receive title until the note was fully paid, and the parties executed additional agreements to address Greenleaf's concerns and clarify remedies for default. Over time, H.A.T. became delinquent in its payments, and Greenleaf lent additional funds to cover repairs after a series of casualty events. Despite proposals to consolidate debts and efforts to sell the property, H.A.T. remained in default. Greenleaf ultimately exercised its right under a memorandum agreement to terminate the contract without notice upon default, retaking possession of the property.H.A.T. then filed suit in the Maine Business and Consumer Docket, alleging various claims, including breach of contract and entitlement to insurance proceeds, while Greenleaf counterclaimed for breach of contract. The court dismissed claims against Greenleaf's counsel and, after a bench trial, ruled in favor of Greenleaf on all claims. The court found that H.A.T. had defaulted on payment obligations, that Greenleaf was justified in terminating the contract, and that H.A.T. was not entitled to insurance proceeds or a setoff. The final judgment awarded Greenleaf costs and attorney fees.On appeal, the Supreme Judicial Court of Maine affirmed the judgment. The Court held that H.A.T. breached the contract by missing payments, Greenleaf had no obligation to provide H.A.T. with insurance proceeds, and H.A.T. was not entitled to notice of a right to cure because the statutory notice provision for foreclosures did not apply to commercial purchasers like H.A.T. The court concluded the statute was intended to protect homeowners, not commercial investors. Judgment was affirmed. View "H.A.T., LLC v. Greenleaf Apartmetns, LLC" on Justia Law

A mother’s parental rights were terminated after her child was born drug-affected, prompting the Department of Health and Human Services to seek a child protection order. The mother, struggling with opioid use disorder, spent significant periods in jail and various treatment facilities. Despite participating in an Adult Treatment and Recovery Court program, she experienced multiple relapses and did not complete her treatment programs. At the time of the termination hearing, she remained in treatment with no clear plan for when she could care for her child.The District Court (Springvale) conducted a hearing on the Department’s petition to terminate parental rights. The court received evidence that the mother had a long-standing substance use disorder and inconsistent participation in treatment. The guardian ad litem (GAL) assigned to the case did not meet several statutory obligations, including meeting the mother in person, observing visits, attending family meetings, and filing timely reports. Nevertheless, the court found the mother unfit based on statutory criteria and concluded that termination was in the child’s best interest. The mother appealed, arguing that the court misunderstood addiction and that deficiencies in the GAL’s performance undermined the best interest determination.The Maine Supreme Judicial Court reviewed the case for clear error and abuse of discretion. The court held that the evidence supported a finding of parental unfitness under at least one statutory ground, and deficiencies in the GAL’s performance did not prevent the trial court from independently determining the child’s best interest. The court also found no abuse of discretion in the trial court’s decision not to explicitly consider a permanency guardianship. Accordingly, the Maine Supreme Judicial Court affirmed the judgment terminating the mother’s parental rights. View "In re Child of Danielle H." on Justia Law

The case concerns an individual who engaged in a lengthy, high-speed police chase that began after a domestic dispute in Brunswick, Cumberland County. The individual left in his girlfriend’s car without permission and was soon pursued by police, first in Sagadahoc County and then back and forth between Sagadahoc and Cumberland Counties. Throughout the chase, he drove recklessly, endangered other drivers, and ultimately collided with a police cruiser, injuring an officer. The entire pursuit was captured on video and presented at trial.A criminal complaint was filed, and a Cumberland County grand jury indicted him on several charges, including eluding an officer and reckless conduct with a dangerous weapon. After it was discovered that some conduct occurred in Sagadahoc County, the State successfully moved to amend the indictment to include both counties. The trial court, sitting as the Cumberland County Unified Criminal Docket, denied the defendant’s motion for acquittal, and the jury found him guilty of eluding an officer and reckless conduct with a dangerous weapon. He was acquitted of some other charges, and this appeal followed.The Maine Supreme Judicial Court reviewed whether the Cumberland County grand jury had the authority to indict for conduct spanning both counties and whether the evidence supported the conviction for reckless conduct with a dangerous weapon. The Court held that both crimes were continuing offenses, committed in both counties, and could be indicted in either. The Court also held that the evidence was sufficient for the jury to find that the defendant used his vehicle as a dangerous weapon. The judgment of conviction was affirmed. View "State of Maine v. Coffill" on Justia Law

Keith Merchant was indicted on eight charges related to repeated sexual offenses against his niece, which occurred over several years beginning when she was twelve years old. The offenses included two counts of gross sexual assault, three counts of unlawful sexual contact, two counts of sexual abuse of a minor, and one count of violating a condition of release. Merchant pleaded guilty to all charges. At sentencing, the court considered testimony from law enforcement and unsworn statements from the victim and her family, noting the lengthy period of abuse and Merchant’s position of trust.The Somerset County Unified Criminal Docket accepted Merchant’s guilty pleas and conducted sentencing in accordance with the three-step analysis established in State v. Hewey and codified in Maine law. The court imposed twenty years’ imprisonment for the first gross sexual assault count and a consecutive ten-year sentence, plus ten years of supervised release, for the second gross sexual assault count. The remaining sentences were set to run concurrently with the first count. Merchant filed for, and was granted, leave to appeal his sentence by the Sentence Review Panel.The Maine Supreme Judicial Court reviewed the case and determined that the sentencing court erred by applying the same sentencing analysis to both primary gross sexual assault counts but issuing different sentences for each, without providing a logical or articulated basis for the disparity. The Court held that a separate, individualized sentencing analysis was required for each primary count that was to run consecutively. Consequently, the Court vacated Merchant’s sentence and remanded the case for resentencing in accordance with its opinion, specifying that no more severe sentence could be imposed on remand. View "State of Maine v. Merchant" on Justia Law