Justia Maine Supreme Court Opinion Summaries

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

Kathleen L. Jellison filed for divorce from Ralph E. Jellison, and the District Court incorporated the parties’ agreement regarding the division of marital assets. Kathleen was awarded the marital home, valued at $250,000 and subject to a $45,823.58 home equity loan, while Ralph received the Verso 401(k) account with a similar value. Both parties and the court agreed this was an equitable division, though Kathleen later contended she had not entered the agreement knowingly and voluntarily, and sought to hold Ralph responsible for half of the home equity debt.After the original judgment, Kathleen filed post-judgment motions, and the District Court amended its judgment to order Ralph to pay $30,000 from his 401(k) to Kathleen, which she was to apply to the home equity loan. Kathleen appealed, arguing the asset division remained inequitable. The Maine Supreme Judicial Court affirmed the amended judgment in Jellison v. Jellison, Mem-24-115. Ralph did not cross-appeal.Subsequently, Ralph filed motions for relief from judgment under Rule 60(a) and then Rule 60(b), arguing that the provision requiring him to pay $30,000 was a mistake. The District Court granted relief under Rule 60(b), striking the payment provision and amending the judgment. Kathleen appealed this order.The Maine Supreme Judicial Court held that the District Court erred in granting Ralph’s Rule 60(b) motion because it conflicted with the appellate mandate affirming the amended judgment. The Supreme Judicial Court clarified that a lower court may not modify matters expressly or impliedly disposed of on appeal, and Rule 60(b) is not a substitute for appellate review or a means to challenge issues not raised on direct appeal. The order granting Ralph’s motion for relief from judgment was vacated, and the case was remanded with instructions to deny the motion. View "Jellison v. Jellison" on Justia Law

On June 15, 2021, two individuals in Portland, Maine reported being struck from behind by a man who inflicted a sharp pain, with one sustaining a wound on her back. The assailant was described as an African-American male with short spiky hair, wearing a green shirt, and carrying a backpack and tablet. Police identified Saad Zackaria as the likely suspect and located him at the Preble Street Resource Center, where staff permitted officers to enter. Zackaria was found fully dressed near the shower room; after he reentered the shower room with the door partially open, officers observed various sharp objects on the floor, including tweezers, a box cutter, and a wire. Zackaria was subsequently arrested.Following his arrest, Zackaria was charged in June 2021 and indicted in August. The Cumberland County Unified Criminal Docket found him incompetent to stand trial in August 2021, but competency was restored in March 2022. Pretrial motions, including a motion to suppress evidence, were denied after a hearing. Delays arose from counsel withdrawal, attorney illness, and a mistrial due to juror unavailability. Zackaria filed motions to dismiss for delay and for a new bail hearing, both denied in early January 2024. After a jury trial in January 2024, Zackaria was found guilty of aggravated assault with a dangerous weapon and two counts of assault with a dangerous weapon and received a sentence including incarceration and probation.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that Zackaria did not have an objectively reasonable expectation of privacy in the shower room or common area of the shelter under the Fourth Amendment, due to the circumstances of his use and the openness of the space. Additionally, the Court found no abuse of discretion in the trial court’s denial of the speedy trial claim, noting that most delays were not attributable to the State or Zackaria, and that the lengthy pretrial detention did not prejudice the defense. View "State of Maine v. Zackaria" on Justia Law

Several property owners in a coastal Maine subdivision disputed the right to use a strip of beach land known as Sea Wall Beach. The plaintiffs owned lots abutting this beach and, in 2021, acquired a deed for a previously unallocated portion of the beach between certain lots. Historically, the defendants and their guests had used this beach area for recreation. The plaintiffs sought a court declaration of their exclusive rights to the beach and an injunction to stop the defendants’ recreational use.The case was initially filed in the Maine Superior Court and later transferred to the Business and Consumer Docket. After a bench trial, the Business and Consumer Docket found that the defendants held an implied easement by subdivision and sale, allowing recreational use of the disputed beach area. The court also considered competing arguments about the location of the northern boundary of Sea Wall Beach but concluded that neither party provided sufficient evidence to fix the boundary on the ground.On appeal, the Maine Supreme Judicial Court reviewed the interpretation of the deeds de novo and the factual determinations for clear error. The Court affirmed the lower court’s judgment, holding that the implied easement for recreational use was properly established by the subdivision plans and historical usage, consistent with precedent. The Court also affirmed the finding that there was insufficient evidence to locate the northern boundary of Sea Wall Beach on the face of the earth, declining to adopt either party’s proposed boundary. The judgment of the Business and Consumer Docket was affirmed. View "Tappen v. Hill" on Justia Law

Denis Lemieux pleaded guilty to domestic violence terrorizing and received a partially suspended sentence with probation. The probation terms required that he not contact certain family members, refrain from criminal conduct, seek evaluations and counseling, and notify probation before moving. Several months later, the State alleged that Lemieux violated his probation by making threatening social media statements about two family members he was barred from contacting, failing to comply with required evaluations and counseling, and not notifying probation of a move.The Kennebec County Unified Criminal Docket held a hearing, found by a preponderance of the evidence that Lemieux violated multiple probation conditions, and partially revoked his probation, imposing a custodial sanction. Lemieux argued at the sanction hearing that the court should consider the constitutionality of the statute under which he was convicted, asserting that if the statute was unconstitutional, his conviction and sentence were void. The court rejected this collateral attack, concluding that only a post-conviction review proceeding—not a probation revocation hearing—was the proper procedure for challenging the validity of the underlying conviction. Lemieux’s post-conviction review petition raising the constitutional issue had been stayed pending appeal.The Maine Supreme Judicial Court reviewed the case. It held that a defendant may not use a probation revocation proceeding to collaterally attack the constitutionality of the statute underlying the conviction. The court reaffirmed that post-conviction review is the exclusive method for challenging the validity of a conviction, except for direct appeal. The decision to affirm the trial court’s revocation of Lemieux’s probation was based on the proper use of procedural avenues for contesting convictions. The judgment of probation revocation was affirmed. View "State of Maine v. Lemieux" on Justia Law

The defendant, an adult male in his fifties, was accused of engaging in unlawful sexual contact with his twelve-year-old great-niece while she was staying overnight at his home in October 2020. The victim disclosed the incident to her mother about a year later after family members encouraged her to speak up due to concerns arising from accusations the defendant had made against the victim’s cousin. The matter was reported to law enforcement and later discussed in a forensic interview. The defendant was subsequently indicted and proceeded to a jury trial.During the trial in the Cumberland County Unified Criminal Docket, significant evidentiary disputes arose. The State sought to introduce testimony regarding a subsequent incident in which the defendant allegedly offered a sex toy to the victim and another individual, arguing its relevance to intent and the relationship between the parties. The defense objected, citing prejudice and late disclosure, and initially, the trial court excluded the evidence but left open the possibility of reconsideration. As the trial progressed and new lines of questioning emerged, the court ultimately allowed this evidence, finding no unfair prejudice. The defense also attempted to introduce evidence that the defendant had threatened the victim’s cousin, theorizing it would demonstrate a motive to fabricate the allegations. The court excluded this testimony, finding it irrelevant because there was no evidence the victim knew of the threats or that her family conspired to fabricate the allegations.The jury found the defendant guilty, and the court imposed a sentence of eight years, with a portion suspended and a probation period. On appeal, the Maine Supreme Judicial Court held that the trial court acted within its discretion in admitting the evidence of the subsequent sexual behavior and did not err in excluding the evidence of threats toward the cousin due to lack of relevance. The judgment of conviction was affirmed. View "State of Maine v. Cardona" on Justia Law

The parties in this case are the parents of a ten-year-old daughter and share equal residential care for her. Their original 2016 order set a child support obligation for the father, but a 2020 amended agreement reduced this obligation to zero, reflecting their arrangement of equal parenting time. In December 2023, both parties filed motions seeking modification of the parental rights and responsibilities order. During the pendency of these motions, the father had a son with another person, but the son was not covered by the child support order at issue.Following a hearing, the Maine District Court (Biddeford) ordered the father to resume paying child support to the mother and denied his request for a downward adjustment based on his obligation to support his new son. The District Court reasoned that under Maine’s statutory scheme, only a nonresidential parent—rather than a coresidential parent like the father—could receive such an adjustment. The court subsequently denied the father’s motion to alter or amend the judgment.On appeal, the Maine Supreme Judicial Court reviewed the statutory interpretation of 19-A M.R.S. § 2006(5)(A) de novo. The Court held that when both parents provide substantially equal care, neither is the “primary care provider” referenced in the statute. Therefore, the statutory provision allowing a child support adjustment for a parent who is not the primary care provider applies. Because the father was legally obligated to support his son in his household and neither party was the primary care provider for their daughter, the Court determined he was entitled to the statutory adjustment. The Maine Supreme Judicial Court vacated the District Court’s child support order and remanded the matter for recalculation consistent with its interpretation. View "Waterman v. Wheeler" on Justia Law

Zakaria Allaf and Stephanie Crosby rented an apartment from Robb Crawford and later from Shoreline Holdings Five, LLC, with the lease requiring a $1,795 security deposit. The tenants experienced a persistent cockroach infestation and, after unsuccessful remediation attempts, agreed with Crawford to terminate the lease early in January 2022. Upon moving out, Allaf and Crosby were assured by Crawford’s agent that the security deposit would be addressed within thirty days, but no response was received. Eventually, Crawford’s attorney informed Crosby that the deposit was being withheld because Crawford did not consider the lease terminated.Allaf and Crosby filed a small claims action in the Maine District Court (Portland), alleging wrongful retention of the security deposit and breach of the implied warranty of habitability. After a trial, the District Court found in their favor, awarding $6,000 in damages (including double damages for the security deposit and damages for breach of habitability), plus attorney fees and costs. Shoreline appealed to the Cumberland County Superior Court, which affirmed the judgment. Shoreline then appealed to the Maine Supreme Judicial Court, challenging the sufficiency of the evidence supporting liability for wrongful retention and arguing that attorney fees should not be awarded in addition to the $6,000 statutory monetary limit for small claims actions.The Maine Supreme Judicial Court affirmed the judgment. It held that sufficient evidence supported the lower court’s finding that the lease had been terminated by agreement and that Shoreline failed to return the security deposit or provide a written explanation. The Court also held that attorney fees awarded under a fee-shifting statute such as 14 M.R.S. § 6034(2) are considered “costs” and are not included within the $6,000 small claims cap set by 14 M.R.S. § 7482. Thus, the award of attorney fees in addition to $6,000 in damages was proper. Judgment was affirmed. View "Allaf v. Shoreline Holdings Five, LLC" on Justia Law