Justia Maine Supreme Court Opinion Summaries

Marc A. Lesperance was found with his dog off-leash in Baxter Woods, Portland, despite a city ordinance requiring dogs to be leashed from April 1 to July 31. A park ranger informed Lesperance of the rule, but Lesperance refused to comply. The ranger, after consulting with a colleague, issued a summons and complaint. The District Court (Portland) fined Lesperance $500, noting it was not his first violation of the ordinance.Lesperance appealed, arguing that the park ranger was not authorized to issue the summons and complaint. He also claimed the city ordinance was preempted by state law and unconstitutionally vague. The court found these arguments without merit, stating the ordinance was clear and not preempted by state law.The Maine Supreme Judicial Court reviewed the case. The court considered whether the park ranger, appointed as a constable, needed to meet specific training requirements to enforce the ordinance. The Attorney General, representing the Maine Criminal Justice Academy, suggested that constables might require less rigorous training than law enforcement officers. The court applied the "de facto officer" doctrine, concluding that Lesperance could not challenge the ranger's authority based on potential training deficiencies. The court affirmed the judgment, validating the ranger's actions as those of a de facto officer. View "City of Portland v. Lesperance" on Justia Law

Kiril Lozanov and Capital City Renewables, Inc. (CCR) appealed a Superior Court decision granting summary judgment in favor of Lily B. Piel. Lozanov and CCR alleged that Piel, a former employee, accessed and disclosed Lozanov’s personal emails without authorization, which included confidential information about a wind project unrelated to CCR. Lozanov claimed that Piel’s actions led to increased child support obligations and health issues due to stress from related litigation.The Superior Court dismissed CCR’s claim for intrusion upon seclusion, as the company did not have a right to privacy in Lozanov’s emails. Lozanov’s claim for intentional infliction of emotional distress was also dismissed, as the court found Piel’s conduct was not outrageous enough to warrant such a claim. The court allowed Lozanov’s intrusion upon seclusion claim to proceed but ultimately granted summary judgment for Piel on all counts, finding no evidence that Piel’s actions caused the alleged damages.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Superior Court’s decision. The court found no evidence that Piel breached any duty owed to CCR or that her actions caused the damages claimed by Lozanov and CCR. The court also concluded that CCR's and Lozanov’s damages were too remote and speculative to support their claims. Additionally, the court noted that public policy considerations barred recovery, as Lozanov’s attempt to hide assets in a child support proceeding was contrary to the best interests of the child and public policy. View "Capital City Renewables, Inc. v. Piel" on Justia Law

Patrick Bolduc and Savannah Getchius were married in 2011 and have three minor children. Bolduc filed for divorce in 2021. After two unsuccessful mediations, a final divorce hearing was held in June 2023. The District Court awarded Bolduc sole parental rights and responsibilities and divided the marital property. The court found that Bolduc's property, purchased before the marriage, appreciated in value during the marriage due to both market forces and marital improvements.The District Court determined that the entire appreciation of the property during the marriage was marital property. The court also ordered Getchius to pay $325 weekly in child support and $10,000 of Bolduc's attorney fees. Bolduc filed motions for further findings and to alter the judgment, which the court mostly denied, except for making limited additional findings.The Maine Supreme Judicial Court reviewed the case. It affirmed the lower court's decision on the classification of the real property, agreeing that Bolduc did not meet his burden to prove that the appreciation was solely due to market forces. The court also upheld the child support order, finding no error in the calculation or the decision not to order Getchius to pay $1,800 for uninsured medical expenses. However, the court found that the attorney fee award was based on an affidavit that included fees unrelated to the divorce proceedings. The court vacated the attorney fee award and remanded for recalculation of the fees properly subject to an award in the divorce action. View "Bolduc v. Getchius" on Justia Law

Matthew W. Pendleton was convicted of manslaughter after a jury trial. Pendleton and the victim, Kevin Curit, were childhood friends, and Curit had moved into Pendleton's home. On January 5, 2023, Pendleton bought alcohol, and later that night, he sent text messages to his daughter, including photos of Curit lying unconscious and statements about injuring his hands. The next morning, Pendleton texted his estranged wife that Curit was dead and later called 9-1-1. The police found Curit dead in a camper with multiple injuries, and the medical examiner concluded that Curit died of strangulation by ligature.The Waldo County trial court admitted screenshots of Pendleton's text messages and his daughter's testimony about his alcohol use and their family dynamic. The court also allowed a jailhouse informant to testify but struck the testimony and instructed the jury to disregard it after the informant mentioned meeting Pendleton in jail. Pendleton was found guilty of manslaughter and sentenced to twenty years in prison, with all but fourteen years suspended, followed by four years of probation.Pendleton appealed to the Maine Supreme Judicial Court, challenging the admission of the text messages and his daughter's testimony, the handling of the jailhouse informant's testimony, and the court's refusal to consider a juror's affidavit during sentencing. The court affirmed the conviction and sentence, finding no abuse of discretion in the trial court's rulings. The court held that the text messages were relevant and not unfairly prejudicial, the daughter's testimony was admissible, the curative measures for the informant's testimony were sufficient, and the juror's affidavit was properly excluded from sentencing considerations. View "State of Maine v. Pendleton" on Justia Law

Moosehead Mountain Resort, Inc., and OFLC, Inc. (collectively Moosehead) filed a civil action against Carmen Rebozo Foundation, Inc., alleging breach of contract, unjust enrichment, and breach of good faith and fair dealing. The dispute arose from a promissory note for $6,350,000 executed by Moosehead and assigned to the Foundation, which allegedly misrepresented the amount due, impacting Moosehead's efforts to sell a ski resort.The Superior Court (Piscataquis County) denied Moosehead’s motion for summary judgment and the Foundation’s motion for relief under Maine Rule of Civil Procedure 56(f), ordering a judicial settlement conference. The parties reached a settlement, agreeing to dismiss the case with prejudice. However, no docket entries were filed within the court's deadline, leading to the case's dismissal with prejudice. Moosehead then filed a motion for reconsideration and to vacate the settlement agreement, which the court denied. The Foundation's motion to enforce the settlement agreement was granted.The Maine Supreme Judicial Court reviewed the case. It affirmed the denial of Moosehead’s motion for reconsideration, finding no abuse of discretion. However, it vacated the judgment enforcing the settlement agreement, concluding that the court lacked jurisdiction to enforce it after the case was dismissed with prejudice. The court noted that the parties failed to take necessary steps to preserve the court's jurisdiction over the settlement agreement before the dismissal. The case was remanded for an order dismissing the motion to enforce the settlement agreement for want of jurisdiction. View "Moosehead Mountain Resort, Inc. v. Carmen Rebozo Foundation, Inc." on Justia Law

Kateryna A. Bagrii sought to establish herself as a de facto parent of two children whose biological parents are John P. Campbell and Jie Chen. Bagrii claimed she had acted as a parent to the children since 2014, after Campbell brought them from China to Ukraine without Chen's consent. Bagrii and Campbell later married and moved to the United States with the children. Bagrii argued that she had taken on full parental responsibilities and that her relationship with the children was in their best interests.The District Court (Newport, Ociepka, J.) dismissed Bagrii’s complaint for lack of standing, finding that although she proved most elements required for de facto parentage, she failed to demonstrate that Chen had fostered or supported her relationship with the children or accepted her parental role. The court noted that Chen had not consented to the children's removal from China and had not known their whereabouts for several years.The Maine Supreme Judicial Court reviewed the case and affirmed the District Court's judgment. The court held that under the Maine Parentage Act, a person seeking de facto parent status must prove that all legal parents who appear and object to the petition have fostered or supported the relationship. The court found that Chen had not implicitly or explicitly consented to Bagrii’s parental role. The court also rejected Bagrii’s request to exercise parens patriae authority, stating that due process principles require proof of consent from all legal parents. Thus, the judgment dismissing Bagrii’s complaint for lack of standing was affirmed. View "Bagrii v. Campbell" on Justia Law

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