Justia Maine Supreme Court Opinion Summaries

Alrig USA Acquisitions LLC, a commercial real estate developer, entered into a purchase and sale agreement with MBD Realty LLC for a property in Portland. MBD was aware that the City of Portland planned to redevelop the area, which would involve condemning part of the property, but did not disclose this to Alrig. The agreement included clauses allowing Alrig to terminate the agreement and receive a refund of its deposit under certain conditions, including eminent domain. Alrig extended the inspection period multiple times, paying additional deposits, and eventually waived its due diligence and title review contingencies, making the deposit nonrefundable except in the event of MBD’s default. Alrig later learned of the redevelopment plans and terminated the agreement, seeking a refund of the deposit, which MBD refused.The Superior Court (Cumberland County) granted MBD’s motion to dismiss Alrig’s complaint for breach of contract and fraud, concluding that MBD had no duty to disclose the redevelopment plans. Alrig appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the Superior Court’s judgment. The court held that the amendment to the agreement unambiguously made the deposit nonrefundable except in the event of MBD’s default, and thus Alrig’s contract claim failed. Additionally, the court found that MBD did not actively conceal the City’s planned condemnation, and there was no special relationship imposing a duty to disclose. Therefore, Alrig’s fraud claim also failed as a matter of law. The court concluded that Alrig was not entitled to relief under any set of facts that might be proven in support of its claims. View "Alrig USA Acquisitions LLC. v. MBD Realty LLC" on Justia Law

The case involves Eastern Maine Medical Center and eight other Maine hospitals (the Hospitals) who filed a 509-page complaint against various businesses and individuals (the Opioid Sellers) involved in the marketing and distribution of prescription opioids. The Hospitals alleged that the Opioid Sellers created illegitimate demand for opioids and unlawfully increased supply, leading to an opioid epidemic that caused the Hospitals to incur high costs for treating patients with opioid misuse, addiction, and dependency, with only partial reimbursement from insurance.The Business and Consumer Docket (Duddy, J.) dismissed the Hospitals' complaint. The court found that the complaint did not comply with the requirement for a "short and plain statement" of the claim but chose to dismiss it based on the legal insufficiency of the claims. The court concluded that the Hospitals could not recover under any of their legal theories, including negligence, public nuisance, unjust enrichment, fraud and negligent misrepresentation, fraudulent concealment, and civil conspiracy. The court also denied the Hospitals' request for leave to amend their complaint.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's dismissal. The court held that the Hospitals' claims were legally insufficient. Specifically, the court found that the Hospitals did not have a direct negligence claim, as they did not suffer harm directly caused by the Opioid Sellers. The fraud and misrepresentation claims failed due to lack of reliance by the Hospitals on the Opioid Sellers' misrepresentations. The unjust enrichment claim was dismissed because the Hospitals did not confer a benefit on the Opioid Sellers. The public nuisance claim failed as the Hospitals did not suffer a special injury different in kind from the public. Lastly, the civil conspiracy claim was dismissed as it required an underlying tort, which was not present. The court concluded that the deficiencies in the complaint could not be remedied by amendment. View "Eastern Maine Medical Center v. Walgreen Co." on Justia Law

Julio Cesar Hernandez-Rodriguez was convicted of two drug offenses after a trial court denied his motion to suppress statements made to Maine Drug Enforcement Agency (MDEA) agents. Hernandez-Rodriguez argued that his statements to one agent should be suppressed because he was subject to unwarned custodial interrogation and that his statements to another agent should be suppressed due to his limited English proficiency, which he claimed prevented him from making a knowing and voluntary waiver of his rights.The trial court found that Hernandez-Rodriguez was in custody during his interactions with the agents and that he had not waived his Miranda rights while speaking with the first agent. However, the court concluded that his statements to the first agent were admissible because they were not the product of interrogation. The court also found that Hernandez-Rodriguez had knowingly and voluntarily waived his Miranda rights when speaking with the second agent, despite his limited English proficiency. Hernandez-Rodriguez entered a conditional guilty plea, preserving his right to appeal the suppression rulings.The Maine Supreme Judicial Court reviewed the case and determined that the trial court erred in not suppressing Hernandez-Rodriguez’s statement identifying a substance as cocaine in response to the first agent’s question, as it was the product of custodial interrogation. However, the court upheld the trial court’s finding that Hernandez-Rodriguez had validly waived his Miranda rights when speaking with the second agent. Given the error in admitting the statement about the cocaine, the court vacated the judgment and remanded the case, allowing Hernandez-Rodriguez the opportunity to withdraw his plea. View "State of Maine v. Hernandez-Rodriguez" on Justia Law

James M. Day appealed a decision by the Town of Hiram Planning Board, which granted Brian and Sarah Schnell a conditional use permit to construct a microbrewery on a property in the Town’s Residential District. Day argued that the Board erred in its interpretation of the "need" factor required by the Town of Hiram’s Zoning Ordinance, which mandates consideration of the necessity of a particular location for the proposed use.The Superior Court (Oxford County) initially remanded the case to the Planning Board for findings of fact. After the Board reaffirmed its decision with additional findings, Day appealed again. The Superior Court then affirmed the Board’s decision, leading Day to appeal to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the Planning Board’s decision directly. The Court found that the Board had misinterpreted the "need" factor by focusing on the Schnells' lack of alternative properties rather than the community's need for the proposed microbrewery at that specific location. The Court clarified that the "need" factor should consider the community's need for the proposed use in the proposed location, not the applicant's personal need for that location.The Court vacated the Superior Court’s judgment and remanded the case to the Town of Hiram Planning Board for further proceedings consistent with its opinion. The Board may reopen the record to allow for additional evidence relevant to the correct interpretation of the "need" factor. View "Day v. Town of Hiram" on Justia Law

Richard W. Kelley was convicted of aggravated trafficking of scheduled drugs after a stop and search of a friend's vehicle in which he was a passenger. Law enforcement conducted the search as part of an investigation into the vehicle's owner for drug trafficking, using a search warrant and two tracking warrants to monitor the vehicle's location. Kelley moved to suppress the evidence obtained through the warrants, arguing that he had a reasonable expectation of privacy in the vehicle.The trial court (Penobscot County, A. Murray, J.) denied Kelley's motion to suppress on the grounds that he lacked standing to challenge the search. Kelley argued that the court should not have addressed his standing because the State had stipulated that he had a reasonable expectation of privacy in the vehicle. However, the court concluded that standing is a threshold issue that must be addressed regardless of the State's stipulation. Kelley was subsequently convicted based on his conditional guilty plea.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the State's stipulation regarding Kelley's standing was not binding on the court. The court further held that Kelley lacked a reasonable expectation of privacy in the vehicle, as he did not have a property or possessory interest in it, nor did he have an interest in the property seized. Therefore, Kelley did not have standing to challenge the search warrants. The judgment of conviction was affirmed. View "State of Maine v. Kelley" on Justia Law

Taylor M. appealed a judgment from the District Court terminating her parental rights to her child, arguing that her due process rights were violated and that the court failed to comply with the Indian Child Welfare Act (ICWA). The child, born prematurely with various medical conditions, required extensive care. Taylor M., a registered member of the Mi’kmaq Nation, was largely absent during the child’s initial hospitalization. The Department of Health and Human Services filed for a child protection order, which was granted, and the child was placed with resource parents.The District Court held a jeopardy hearing in January 2023, finding clear and convincing evidence of jeopardy due to Taylor M.’s inability to care for the child. The court scheduled several hearings, but delays occurred, and the child’s resource parents moved out of state with the Department and tribe’s agreement. In October 2023, the Department filed a petition to terminate Taylor M.’s parental rights. At the consolidated hearing in January 2024, the court heard testimony from various parties, including the ICWA director for the Mi’kmaq Nation.The Maine Supreme Judicial Court reviewed the case and found that the District Court complied with ICWA requirements. The court determined that the Department made active efforts to reunify the family and that Taylor M. did not take significant steps to address the jeopardy. The court also found beyond a reasonable doubt that continued custody by Taylor M. would likely result in serious emotional or physical damage to the child. The court affirmed the termination of Taylor M.’s parental rights, concluding that the child’s placement with the resource parents was appropriate and in the child’s best interest. View "In re Child of Taylor M." on Justia Law

Robert E. Dupuis and twelve other plaintiffs filed lawsuits against the Roman Catholic Bishop of Portland, seeking damages for sexual abuse allegedly perpetrated by the Bishop’s clergy when the plaintiffs were minor children. Their claims were previously barred by the statute of limitations. The Bishop moved for judgment on the pleadings, arguing that 14 M.R.S. § 752-C(3) (2022), which purports to revive the plaintiffs’ claims, deprives the Bishop of a constitutionally protected vested right.The Business and Consumer Docket (McKeon, J.) denied the Bishop’s motions but reported its orders to the Maine Supreme Judicial Court under Maine Rule of Appellate Procedure 24(c). The court accepted the report to determine whether the retroactive application of section 752-C(3) is constitutional.The Maine Supreme Judicial Court held that the retroactive application of section 752-C(3) contravenes centuries of precedent and multiple provisions of the Maine Declaration of Rights, as well as the Constitution’s provisions regarding separation of powers. The court concluded that once a statute of limitations has expired for a claim, a right to be free of that claim has vested, and the claim cannot be revived. Therefore, section 752-C(3) is unconstitutional as applied to expired claims. The court remanded the case for further proceedings consistent with this opinion. View "Dupuis v. Roman Catholic Bishop of Portland" on Justia Law

A District Court in Caribou, Maine, issued a judgment in February 2024 regarding the parental rights and responsibilities of a child born to Andrew M. Landeen and Ashley Burch, who were former romantic partners but never married. The court granted primary physical residence to Burch and visitation rights to Landeen. Additionally, the court changed the child's last name to "Landeen" without providing specific findings or comments on the decision. Burch appealed the name change, and Landeen cross-appealed the allocation of parental rights and responsibilities.The District Court's judgment was based on the best interest of the child, considering factors such as the parents' ability to cooperate and the child's emotional and physical safety. The court found that Landeen's persistent anger towards Burch and his inability to manage frustration appropriately were detrimental to the child's best interest. Consequently, the court allocated primary parental rights to Burch while allowing Landeen visitation rights and the right to be informed of major decisions concerning the child.The Maine Supreme Judicial Court reviewed the case and found that the District Court's allocation of parental rights and responsibilities was supported by the record and did not constitute an abuse of discretion. However, the Supreme Judicial Court vacated the portion of the judgment changing the child's last name. The court held that the father’s desire to change the child's surname, based solely on tradition and without supporting evidence, did not meet the statutory requirement of showing "good cause" or that the change was in the child's best interest. The court emphasized that both parents have equal rights in naming their child and that any name change must be justified by the child's best interest. View "Landeen v. Burch" on Justia Law

Billy L. Beaulieu was charged with criminal OUI (Class C) under Maine law. He filed a motion to dismiss the charges, claiming immunity under Maine’s Good Samaritan statute, which provides immunity from prosecution if a call for assistance for a suspected drug-related overdose is made at the location of a medical emergency. Beaulieu argued that the statute’s requirements were met because a driver who saw his car beside an interstate highway exit asked the police to check on the vehicle, suspecting a medical event.The Cumberland County trial court denied Beaulieu’s motion to dismiss. The court found that the witness was concerned about a medical event and reported it to the police, who then checked on Beaulieu. However, the court concluded that the situation did not meet the statutory requirements for immunity because the call was not for a suspected drug-related overdose, and there was no medical emergency.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the Good Samaritan statute’s plain language requires the call for assistance to be specifically for a suspected drug-related overdose and that the location must be a medical emergency. The court found that the witness’s concern about a general medical event did not satisfy the statute’s requirements. Additionally, there was no evidence of a medical emergency at the scene. Therefore, Beaulieu was not entitled to immunity under the Good Samaritan statute, and the denial of his motion to dismiss was affirmed. View "State of Maine v. Beaulieu" on Justia Law

Dennis W. Lowery was convicted of gross sexual assault after a jury trial in Cumberland County. The incident occurred on December 19, 2021, when Lowery entered the victim's room at a Portland inn without her knowledge or permission and sexually assaulted her while she was asleep. The victim identified Lowery to the police, who found him nearby. DNA evidence linked Lowery to the crime.The trial court denied Lowery's motions to dismiss and for a new trial, which were based on alleged discovery violations by the State. Lowery argued that the State failed to disclose information about certain witnesses and evidence handlers in a timely manner. The court allowed the testimony of these witnesses, reasoning that Lowery was aware of their roles and had the opportunity to cross-examine them. The court also denied Lowery's motion for a judgment of acquittal on the gross sexual assault charge but granted it on a burglary charge due to a defect in the indictment.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decisions. The court held that the trial court did not abuse its discretion in handling the alleged discovery violations, as Lowery was not prejudiced to the extent that it deprived him of a fair trial. The court also found no obvious error in the admission of evidence regarding Lowery's pre-arrest silence, as Lowery did not invoke his right to remain silent before being questioned by the police. The court concluded that the trial court's actions were appropriate and did not violate Lowery's due process rights. View "State of Maine v. Lowery" on Justia Law