Justia Maine Supreme Court Opinion Summaries

Snakeroot Solar, LLC, sought a good-cause exemption from the Public Utilities Commission (PUC) to extend the deadline for its photovoltaic generating facility in Pittsfield to reach commercial operation and participate in Maine’s net energy billing (NEB) program. The facility needed to be operational by December 31, 2024, but delays in the interconnection process and the time required for grid upgrades made this deadline unachievable. Snakeroot argued that these delays were outside its control and warranted an exemption.The PUC denied Snakeroot’s petition, finding that the delays were inherent to the interconnection process and not external. The PUC noted that the cluster study process, which took slightly longer than average, and the time required for grid upgrades were typical and did not constitute external delays. Snakeroot appealed, arguing that the PUC misinterpreted the statute and that the delays were indeed external and beyond its control.The Maine Supreme Judicial Court reviewed the case and upheld the PUC’s decision. The Court found that the PUC’s interpretation of the statute was reasonable and aligned with the legislative intent to limit the number of projects eligible for the NEB program to control electricity rates. The Court also determined that the PUC’s findings were supported by substantial evidence, including the typical duration of cluster studies and the standard lead times for equipment procurement. The Court concluded that the PUC did not abuse its discretion in denying the exemption, as the delays experienced by Snakeroot were part of the normal interconnection process and not extraordinary. View "Snakeroot Solar, LLC v. Public Utilities Commission" on Justia Law

Alex Titcomb and four other registered Maine voters challenged the wording of a ballot question for citizen-initiated legislation that would amend Maine voting laws. They argued that the question did not meet statutory requirements to be understandable and not misleading to a reasonable voter. The proposed legislation included various changes to election laws, such as requiring photo ID for voting, ending ongoing absentee voting for seniors and people with disabilities, and other modifications.The Superior Court (Cumberland County) affirmed the Secretary of State’s decision on the wording of the ballot question. The court found that the language used in the question was understandable and not misleading. Titcomb appealed this decision, arguing that the question improperly singled out the effect on seniors and people with disabilities and used confusing terms.The Maine Supreme Judicial Court reviewed the case and upheld the Superior Court’s judgment. The court concluded that the ballot question was not misleading and was understandable to a reasonable voter. The court noted that the language used in the question accurately reflected the proposed legislation and that the terms used were clear to an informed voter. The court also found that the length of the question, while longer than usual, was necessary to convey the various changes proposed in the legislation. The judgment of the Superior Court was affirmed. View "Titcomb v. Secretary of State" on Justia Law

Pamela J. (Tower) Weinle appealed a divorce judgment from the District Court (Skowhegan), which divided marital property and awarded Alan R. Tower spousal support and attorney fees. Weinle contested the spousal support, property distribution, and attorney fees. Tower died after the judgment and during the appeal process.The District Court awarded Tower $2,000 per month in general spousal support, $500 per month in reimbursement spousal support, and $12,325 in attorney fees. The court found that Weinle had engaged in economic misconduct by purchasing and selling property without Tower's knowledge and failing to comply with discovery obligations, which increased litigation costs. The court also noted that Weinle had a substantial income and financial resources, while Tower had limited income and poor health.The Maine Supreme Judicial Court overruled its previous decision in Panter v. Panter, which required dismissal of an appeal if a party died during its pendency. The court held that the death of a party does not moot the appeal regarding property rights. The court affirmed the District Court's judgment, finding no error in the spousal support award, property distribution, or attorney fees. The court noted that the spousal support obligation ceased upon Tower's death, as the divorce judgment did not specify that the support survived the death of either party. View "Weinle v. Estate of Tower" on Justia Law

Townsend Thorndike was convicted of unlawful sexual contact and visual sexual aggression against a child. The charges stemmed from alleged sexual abuse that occurred in the summer of 2021 when the victim was six years old. The State sought to admit a video recording of the victim’s forensic interview under a statutory hearsay exception. Thorndike argued that the statute allowing the video’s admission was unconstitutionally enacted as emergency legislation and violated the separation of powers clause in the Maine Constitution.The trial court initially granted the State’s motion to admit the video but later vacated its order, concluding the statute did not apply retroactively to pending cases. The State then sought and obtained an emergency legislative amendment clarifying the statute’s retroactive applicability. The trial court reinstated its original order, allowing the video’s admission. Thorndike was subsequently convicted on all counts, and the court sentenced him to fourteen years of imprisonment with all but eight years suspended, plus six years of probation.The Maine Supreme Judicial Court reviewed the case and upheld the trial court’s decision. The Court found that the emergency enactment of the statutory amendment was constitutionally valid, as the preamble expressed sufficient facts to constitute an emergency. The Court also determined that the legislative action did not violate the separation of powers doctrine, as it did not mandate the admission of evidence but clarified the statute’s applicability to pending cases. The Court affirmed Thorndike’s conviction and the trial court’s admission of the forensic interview video. View "State of Maine v. Thorndike" on Justia Law

Josh Rinaldi, an inmate at the Maine Correctional Center, slipped on an untreated patch of ice on a paved road within the correctional center, referred to as the "Runway," and broke his ankle. Rinaldi filed a twelve-count complaint asserting various tort claims, arguing that the State was not immune under the Maine Tort Claims Act (MTCA) due to an exception for injuries sustained in or on an appurtenance to a public building.The Superior Court (Androscoggin County) granted Rinaldi's motion for partial summary judgment, ruling that the Maine Correctional Center is a public building under the MTCA and that the Runway is an appurtenance to the correctional center's buildings. The State appealed, arguing that it was immune from liability under the MTCA and that the Runway did not fall under any exceptions to the MTCA.The Maine Supreme Judicial Court reviewed the case and concluded that the Runway is not an appurtenance to the correctional center's buildings. The court applied a three-element test to determine whether the Runway was an appurtenance: physical annexation to the realty, adaptation to the realty, and intent to be irremovable from the realty. The court found that the Runway was not physically annexed to the buildings, was not specially adapted to the buildings, and was not intended to be irremovable from the realty. Therefore, the Runway did not meet the criteria for an appurtenance under the MTCA.The Maine Supreme Judicial Court vacated the Superior Court's judgment granting Rinaldi's motion for partial summary judgment and remanded the case for entry of summary judgment in favor of the State, concluding that the State was immune from liability under the MTCA. View "Rinaldi v. Maine Correctional Center" on Justia Law

Sharon Andersen filed a complaint against the Department of Health and Human Services (DHHS) alleging hostile-work-environment disability discrimination under the Maine Human Rights Act (MHRA). Andersen, who worked for DHHS from 2005 to 2019, claimed that from July 2018 to August 2019, she experienced increased stress and anxiety due to her workload and interactions with her supervisor. She reported panic attacks and was eventually diagnosed with post-traumatic stress disorder (PTSD). Andersen requested reasonable accommodations, including reassignment, which were denied. She went on medical leave in January 2019 and resigned in August 2019, claiming constructive discharge.The Superior Court (Cumberland County) granted summary judgment in favor of DHHS, concluding that Andersen’s claim was time-barred. The court found that the only actions within the statutory limitations period were DHHS’s refusal to reassign Andersen and her resignation, neither of which were discriminatory in themselves or indicative of a continuing violation.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court’s decision. The Court held that Andersen did not make a prima facie showing of a continuing violation. The Court determined that Andersen’s resignation, occurring more than seven months after she went on medical leave, was too disconnected from the alleged hostile work environment to qualify as a constructive discharge. Additionally, the Court noted that DHHS’s refusal to reassign Andersen was not a required reasonable accommodation under the Americans with Disabilities Act (ADA) and the MHRA. Therefore, Andersen’s claim was deemed untimely, and the summary judgment in favor of DHHS was affirmed. View "Andersen v. Department of Health and Human Services" on Justia Law

Monika McCallion, Brandan McCallion, and Old Bears, LLC (collectively, the McCallions) appealed a judgment affirming the Bar Harbor Board of Appeals' decision to uphold the issuance of a 2023 short-term rental registration to W.A.R.M. Management, LLC. The Town of Bar Harbor requires annual registration of short-term rental properties, classifying them as either VR-1 or VR-2. W.A.R.M. Management, LLC owns two VR-2 properties, one of which is central to this dispute. The property in question is in a district where VR-2s are generally prohibited unless they were registered before December 2, 2021. W.A.R.M. submitted renewal applications and fees for both properties in January 2023, but due to a malfunction in the Town's online portal, one application was lost, and the registration was not renewed by the May 31 deadline. The Town's code enforcement officer (CEO) later issued a registration for the property in October 2023 after determining that W.A.R.M. had timely submitted its renewal application.The McCallions filed an administrative appeal with the Bar Harbor Board of Appeals, arguing that the CEO could not renew the registration after the deadline. The Board upheld the CEO's actions after a de novo hearing. The McCallions then filed a Rule 80B complaint in the Superior Court, which affirmed the Board's decision without addressing the Town's mootness argument. While the case was pending, W.A.R.M. received a 2024 registration for the property, which the McCallions did not contest.The Maine Supreme Judicial Court reviewed the case and determined that the appeal was moot because the 2023 registration had been superseded by the 2024 registration, which was not appealed. The court concluded that even if it ruled in favor of the McCallions regarding the 2023 registration, it would have no practical effect since the 2024 registration was final and not subject to review. The court dismissed the appeal as moot, noting that no exceptions to the mootness doctrine applied in this case. View "McCallion v. Town of Bar Harbor" on Justia Law

Damion L. Butterfield was convicted of murder and other offenses after pleading guilty following a trial but before the jury announced its verdict. He sought to withdraw his guilty plea, arguing that the court abused its discretion by denying his request and his motion for a new trial. Butterfield also appealed his thirty-five-year prison sentence.The trial court (Cumberland County, MG Kennedy, J.) denied Butterfield's motion to withdraw his plea and his motion for a new trial. The court found that Butterfield had multiple opportunities to discuss his options with counsel and that his plea was made voluntarily and with full knowledge of the consequences. The court also noted that Butterfield did not assert his innocence and that the plea was entered after thorough colloquies. The court sentenced Butterfield to thirty-five years in prison, consistent with the joint recommendation of the parties.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the trial court did not abuse its discretion in denying Butterfield's motion to withdraw his plea, as the plea was made voluntarily and with full understanding of the consequences. The court also dismissed Butterfield's appeal of his sentence, noting that discretionary review is unavailable for sentences imposed pursuant to a joint recommendation of the parties. View "State of Maine v. Butterfield" on Justia Law

Raymond Ellis Jr. was convicted of robbery and possession of a firearm by a prohibited person. On August 5, 2023, Ellis, armed with a handgun, and a juvenile accomplice, armed with a sawed-off shotgun, robbed the Big Apple convenience store in Madison. They wore masks, threatened the store clerk, and stole cash from the registers. A third person acted as a lookout. Ellis was sentenced to twenty-five years for robbery, with all but twenty years suspended, and four years of probation, plus a concurrent three-year term for the firearm possession charge.The jury found Ellis guilty of robbery, criminal threatening with a dangerous weapon, and theft by unauthorized taking. The court found him guilty of possession of a firearm by a prohibited person after Ellis waived his right to a jury trial on that count. The court merged the criminal threatening and theft counts with the robbery count for sentencing purposes. Ellis appealed, arguing entitlement to a missing-witness jury instruction and errors in the sentencing process.The Maine Supreme Judicial Court reviewed the case. Ellis contended that the jury should have been instructed to infer that a missing witness would not have corroborated the State’s theory. The court reaffirmed its stance from State v. Brewer, holding that no such inference is permissible. The court also addressed Ellis’s claim of double-counting sentencing factors, noting that the sentencing court improperly considered Ellis’s failure to take responsibility as an aggravating factor. The court vacated Ellis’s sentence and remanded for resentencing, affirming the judgment of conviction in all other respects. View "State of Maine v. Ellis" on Justia Law

Peter A. Smith visited Mercy Hospital twice in June 2017 with symptoms indicative of Lyme disease. Dr. John R. Henson misdiagnosed him on both occasions, leading to a lack of appropriate treatment. Smith subsequently developed Lyme carditis and died on July 2, 2017. His parents, Angela M. Smith and Richard T. Smith Jr., as co-personal representatives of his estate, filed a medical negligence lawsuit against Henson, Mercy Hospital, and Eastern Maine Healthcare Systems.The Superior Court (Cumberland County) ruled that Maine’s Wrongful Death Act allowed recovery for pecuniary injuries even if the decedent would not have provided financial support to the beneficiaries. A jury found the defendants liable and awarded damages, including $2 million for pecuniary injury to Smith’s parents, despite no evidence that Smith would have financially supported them.The Maine Supreme Judicial Court reviewed the case. The court held that the applicable wrongful death statute authorized recovery for pecuniary injury only when the death deprived one or more of the people identified in the statute of prospective financial gain. The court concluded that damages for such a loss were not available when the loss was asserted only by the estate. Consequently, the court vacated the portion of the judgment awarding damages for pecuniary injury. All other aspects of the judgment were unaffected, and the case was remanded for entry of a modified judgment consistent with the opinion. View "Smith v. Henson" on Justia Law