Justia Maine Supreme Court Opinion Summaries

The defendant was convicted after a jury trial of aggravated attempted murder, elevated aggravated assault, kidnapping, and domestic violence aggravated assault. The essential facts established at trial were that the defendant assaulted his domestic partner over several hours, including strangling her, bludgeoning her with a hammer, threatening her, forcing her to smoke methamphetamine, and causing more than twenty skull fractures and other severe injuries. The victim escaped and was recaptured, with the defendant continuing his attacks until police intervened and shot him. The victim suffered permanent physical injuries.After the defendant was indicted, he moved to suppress statements made to detectives while hospitalized, arguing his waiver of the right to silence was not voluntary. The Penobscot Unified Criminal Docket (Ociepka, J.) held a suppression hearing and denied the motion, finding the waiver voluntary. Following a three-day jury trial, the jury returned guilty verdicts on all counts. At sentencing, the court imposed life imprisonment for aggravated attempted murder and concurrent sentences on the other charges. The defendant appealed his convictions and sentence, including the suppression ruling, sufficiency of the evidence, proportionality of the life sentence, and alleged imposition of a “trial penalty.”The Maine Supreme Judicial Court reviewed the case and affirmed the convictions and sentence. The court held that law enforcement scrupulously honored the defendant’s invocation of the right to silence, and his subsequent waiver was voluntary. It found sufficient evidence for the jury to conclude “extreme cruelty” occurred, affirming the aggravated attempted murder conviction. The court held that a life sentence was not unconstitutionally disproportionate, and recommended but did not require express analysis of Shortsleeves factors for aggravated attempted murder sentencing. Finally, it determined there was no evidence the sentencing court imposed a trial penalty for exercising the right to trial. Judgment affirmed. View "State of Maine v. Carter" on Justia Law

An employee suffered a work-related injury in 1985 while married to his then-spouse. At the time, the couple shared finances and property. Years later, the couple divorced, and the former spouse later remarried. Despite these changes, the original injury continued to affect the employee, ultimately leading to his death in 2020. Following his death, the former spouse sought death benefits under Maine’s workers’ compensation statute, claiming she met the dependency requirements.After a contested hearing, an Administrative Law Judge of the Workers’ Compensation Board found that the former spouse was living with and dependent on the employee at the time of his injury. The judge further concluded that she had not become the dependent of another person, interpreting the statute to require dependency only at the time of injury, not at the time of death. S.D. Warren, the employer, challenged this interpretation, but the Appellate Division of the Workers’ Compensation Board affirmed the judge’s decision, holding that dependency at the time of injury was sufficient.The Supreme Judicial Court of Maine reviewed the case. It held that the statute unambiguously ties eligibility for death benefits to dependency at the time of injury, not at the time of death, unless the statute states otherwise. The Court found that the plain language of the relevant statutory provisions, as well as prior precedent, supported this interpretation. Therefore, the Court affirmed the Appellate Division’s decision, upholding the award of death benefits to the former spouse based solely on her dependency status at the time of the employee’s injury. View "Brewster v. S.D. Warren/Sappi N.A." on Justia Law

The case concerns Nathan Lee, who was convicted of domestic violence aggravated assault and domestic violence criminal threatening with a dangerous weapon, both involving his daughter as the victim. The first incident occurred in 2018, when Lee pointed a gun at his daughter during an argument and threatened her, clicking the trigger and saying it was good the gun was not loaded. In a separate incident in 2020, during another argument, Lee pinned his daughter against a door by her throat until she lost consciousness. Both incidents took place in the family home, with no other witnesses present. The State relied solely on witness testimony, with no physical evidence introduced.The Lincoln County Unified Criminal Docket held a two-day jury trial in October 2024. The State presented four witnesses, but only the daughter testified about the underlying incidents. The other witnesses spoke about family dynamics. Lee presented two witnesses for impeachment. During trial, the prosecutor attempted to lay a foundation for a law enforcement witness to opine about the victim’s credibility, but the defense objected and the line of questioning was abandoned. In closing argument, the prosecutor commented that he thought the victim’s mother was "pretty honest," but Lee did not object. The jury found Lee guilty on both counts, and the trial court sentenced him to concurrent prison terms.The Maine Supreme Judicial Court reviewed Lee’s claims of prosecutorial error. The Court found that the prosecutor committed plain error both by attempting to elicit inadmissible opinion testimony and by improperly vouching for a witness in closing argument. However, neither error affected Lee’s substantial rights or deprived him of a fair trial, as the improper testimony was never actually presented to the jury, and the witness commented upon in closing was not an eyewitness to the alleged crimes. The Court affirmed the judgment of conviction. View "State of Maine v. Lee" on Justia Law

The defendant was convicted in the Cumberland County Unified Criminal Docket of elevated aggravated assault, reckless conduct with a dangerous weapon, possession of a firearm by a prohibited person, and criminal mischief. He was sentenced to fifteen years’ imprisonment with all but seven years suspended and four years of probation on the primary count, with concurrent sentences on the other counts. The key issue arose because both the elevated aggravated assault and reckless conduct convictions were based on the same conduct.The defendant appealed, arguing that the failure to merge the convictions violated the double jeopardy clause. The Maine Supreme Judicial Court previously agreed, vacated the sentence, and remanded for resentencing on a single conviction reflecting the merged counts. On remand, the trial court held a resentencing hearing, where the defendant presented evidence of rehabilitation and remorse since the original sentencing. Despite these presentations, the trial court declined to conduct a new sentencing analysis and imposed the same sentence as before, simply merging the counts to address the double jeopardy issue.The Maine Supreme Judicial Court reviewed the legality of the resentencing de novo. The Court held that the trial court erred by not conducting a new sentencing analysis as required by statute and by its prior mandate. The Court further clarified that upon resentencing, the trial court has authority to consider post-sentencing mitigating information, including evidence of rehabilitation. The judgment was vacated again, and the case was remanded for a new sentencing proceeding at which both parties must be heard and a de novo sentencing analysis must be conducted consistent with statutory requirements. View "State of Maine v. Ali" on Justia Law

The Maine Department of Health and Human Services conducted a competitive bidding process in 2023 to award contracts for medical nonemergency transportation services for MaineCare and Children’s Health Insurance Program recipients. Penquis C.A.P., Inc., previously the incumbent provider for two regions, submitted bids for four regions but lost to ModivCare Solutions, LLC, which received the highest scores and was awarded contracts for all eight transit regions. Penquis CAP challenged the awards for four regions, asserting irregularities in the evaluation process and seeking access to additional DHHS records through Freedom of Access Act requests.Penquis CAP first pursued administrative appeals before a Department of Administrative and Financial Services (DAFS) appeal committee, which held a hearing and ultimately validated the contract awards to ModivCare. Penquis CAP then sought judicial review in the Superior Court (Penobscot County), which was transferred to the Business and Consumer Docket. After briefing and oral argument, the Business and Consumer Docket affirmed the appeal committee’s decision, finding no legal or procedural error in the bidding and award process. Penquis CAP subsequently appealed to the Maine Supreme Judicial Court, which stayed the contract awards pending appeal.The Maine Supreme Judicial Court reviewed the administrative record for errors of law, unsupported factual findings, or abuse of discretion. The Court held that Penquis CAP was not entitled under statute or the Administrative Procedure Act to delay the hearing until all FOAA requests were fulfilled, nor to obtain evidence beyond what it already possessed. The Court found no clear and convincing evidence justifying invalidation of the contract awards, and affirmed the judgment, lifting the stay on the awards. View "Penquis C.A.P., Inc. v. Department of Administrative and Financial Services" on Justia Law

A veteran with post-traumatic stress disorder sought housing in Maine and contacted D&L Apartments about an available unit. During a phone conversation, the landlord, Darrell Sproul, stated that no dogs were allowed. When the prospective tenant specifically asked if the policy included service or “federally protected” dogs, Sproul again said no dogs and advised not to apply. The prospective tenant, who anticipated soon receiving a service dog, did not pursue the rental further. The Maine Human Rights Commission filed a complaint against D&L Apartments and Sproul, alleging unlawful disability discrimination under the Maine Human Rights Act (MHRA), based on three theories: refusal to permit a service animal, making a discriminatory statement, and refusing to rent because of disability.The Kennebec County Superior Court denied D&L’s motion for summary judgment and held a bench trial. The court found in favor of the Commission, concluding that D&L violated two provisions of the MHRA: (1) by refusing to permit the use of a service animal, in violation of 5 M.R.S. § 4582-A(3), and (2) by making a statement indicating a discriminatory limitation based on disability, in violation of 5 M.R.S. § 4581-A(1)(C). The court found it unnecessary to address the third theory. As remedies, the court ordered fair-housing training, the creation of a policy on assistance animals, and imposed a $10,000 civil penalty.On appeal, the Maine Supreme Judicial Court affirmed the Superior Court’s judgment. It held that Sproul’s statements constituted an unlawful indication of a limitation or discrimination based on disability, and that the statutory protection against refusing the use of a service animal extends to prospective tenants, even if they do not yet possess the animal. The court found no error in the trial court’s interpretation or application of the MHRA and upheld the finding of liability and the remedies imposed. View "Maine Human Rights Commission v. D&L Apartments" on Justia Law

On the evening of January 1, 2023, Elizabeth Gurney, aged eighteen, hosted a party at the house she shared with her mother, Holly Gurney, in Lewiston, Maine. Holly was out of town but had instructed Elizabeth that she could have a small gathering with restrictions on the number of guests and no alcohol. The party grew unexpectedly large and unruly, with many uninvited guests, including individuals involved with drugs. After several masked, uninvited individuals returned to the party and refused to leave, Elizabeth asked Zachary Wilson, a guest, to help remove them. While Wilson escorted one of the intruders outside, the intruder shot and injured him.Wilson filed suit in the Androscoggin County Superior Court against Elizabeth and Holly Gurney, alleging premises liability and, as to Holly, negligent entrustment. He argued that the Gurneys owed him a duty to maintain safe premises and to protect him from foreseeable harm, and that Holly was negligent in entrusting the house to Elizabeth. The Superior Court granted summary judgment to the Gurneys, determining that they did not owe a duty to protect Wilson from the criminal act of a third party and that negligent entrustment does not apply to real property. Wilson appealed this decision.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the lower court’s judgment. The Court held that neither of the Gurneys owed Wilson a duty to protect him from the criminal actions of third parties under the circumstances, as no special relationship existed between the parties and the Gurneys did not create a situation of foreseeable, high risk. The Court also held that the tort of negligent entrustment applies only to chattels, not to real property, and declined to expand the doctrine. Thus, summary judgment for the Gurneys was upheld. View "Wilson v. Gurney" on Justia Law

After a divorce in September 2024, one party engaged in a series of acts directed at the other, including making a sexually suggestive and violent Facebook post, slamming a metal mailbox while delivering a child support payment despite requests for direct deposit, and posting a “warning poster” in the other party’s neighborhood implying she was a “black widow.” The recipient of these actions, who had previously experienced the other party’s alcohol misuse, anger, suicidal statements, and gun ownership, filed for a protection from abuse order.The District Court in Rockland issued a temporary protection order and then, after a final hearing, found by a preponderance of the evidence that the actions constituted abuse under Maine law, specifically 19-A M.R.S. § 4102(1)(B) as amended in 2024. The court determined that the conduct placed the plaintiff in fear of bodily injury, and that the defendant consciously disregarded a substantial risk that his speech would cause such fear. The court issued a final protection order prohibiting contact. The defendant appealed, arguing that his conduct constituted protected speech under the First Amendment, referencing Counterman v. Colorado, 600 U.S. 66 (2023), and challenging the sufficiency of the evidence regarding recklessness and “true threats.”The Maine Supreme Judicial Court reviewed the case, applying clear error review to the trial court’s factual findings and de novo review to the First Amendment challenge. The court held that the trial court properly considered the context and history between the parties, and that sufficient evidence supported the finding that the defendant’s actions and communications amounted to a course of conduct that placed the plaintiff in reasonable fear of bodily injury, and that he acted recklessly. The judgment of the District Court was affirmed. View "Doe v. Weymouth" on Justia Law

The case concerns a defendant who was convicted in two separate matters in Hancock County, Maine. In the first, he was found guilty by a jury of several offenses, including domestic violence aggravated assault with a dangerous weapon, after an incident in June 2020 in which he assaulted his romantic partner in his home, engaged in multiple acts of violence, and threatened both her and her child. In the second, he entered a conditional guilty plea to tampering with a witness. The court sentenced him to concurrent terms totaling twenty-four years, with all but twenty-two years suspended, and six years of probation.After the trial, the defendant argued that the trial court erred in three main ways: (1) by denying him an evidentiary hearing regarding funds seized in an unrelated drug case, which he claimed violated his rights to counsel and due process; (2) by failing to provide a specific-unanimity jury instruction and denying his post-judgment request for a mental-condition examination; and (3) by increasing his sentence based on findings about firearms, his age, and his lack of acceptance of responsibility.The Maine Supreme Judicial Court found it lacked jurisdiction to review the issues related to the seized funds, as they were tied to a separate case. The Court held that no specific-unanimity instruction was required for the counts at issue, the trial court did not err in denying the request for a mental-condition examination, and the sentencing court properly considered the presence of firearms, the defendant’s age, and his lack of acceptance of responsibility. However, the Court concluded that certain counts should have been merged to avoid double jeopardy. The judgment was affirmed, but the sentence was vacated in part and the matter remanded for resentencing consistent with the required mergers. View "State of Maine v. Witham" on Justia Law

A gravel pit in the Town of Sabattus was granted conditional approval in 2003 to mine gravel from a four-acre area adjacent to F. Sanborn Road, with requirements for buffer zones and slope ratios. The Abutters, who own properties along the shore and use the road for access, raised concerns about compliance with these conditions. In late 2023, the Town found violations, including expansion beyond the permitted area and encroachment into the buffer zone and Shoreland Zoning area. Poirier, the operator, agreed to cease excavation, and the Town issued a notice of violation.Following negotiations, the Town filed a land use complaint and proposed a consent judgment in spring 2025. The District Court in Lewiston allowed the Abutters to intervene and heard their objections to the consent judgment, which required Poirier to execute a new reclamation plan, stabilize the berm, create a thirty-foot reclaimed buffer, and cease further mineral extraction. The Abutters argued that the judgment violated state law and local ordinances by not requiring a fifty-foot buffer and permitting ongoing violations. The District Court approved the consent judgment in September 2025, and the Abutters appealed.The Maine Supreme Judicial Court reviewed the matter de novo, applying the standard from Pike Industries, Inc. v. City of Westbrook. The Court held that the consent judgment did not violate state performance standards, as it required compliance with Maine law and allowed for enforcement if violations occurred. The judgment was consistent with the Town's ordinances, as the ordinances applied to new development or active excavation, not reclamation. The Court found no impermissible effects on third parties and no violation of public policy, concluding that the judgment was fair, adequate, and reasonable. The judgment of the District Court was affirmed. View "Town of Sabattus v. L.P. Poirier & Son, Inc." on Justia Law