Justia Maine Supreme Court Opinion Summaries

In this case, a man in his mid-fifties was accused of unlawful sexual contact with a fourteen-year-old girl who lived in the same household with him and her mother, his then-girlfriend. The alleged incident occurred in late 2021 or early 2022, when the man intentionally touched the victim's genitals for sexual gratification. A criminal complaint was filed in January 2023, charging him with unlawful sexual contact during a period between November 18, 2021, and January 31, 2022. He pleaded not guilty.Prior to trial in the Aroostook County Unified Criminal Docket, the defendant sought to compel production of an electronic “change log” associated with the police report, arguing it was necessary for his defense. After a hearing, the trial court found that the change log would not reveal any information beyond what had already been disclosed and denied the motion. During the trial, the State was permitted to recall the victim’s mother to clarify inconsistencies in her testimony regarding when the defendant lived in her home, after a recess in which the prosecutor spoke to her privately. The defendant objected, but the court allowed the recall, limiting the testimony to clarifying the timeline. Additionally, during closing arguments, the prosecutor repeatedly used the phrase “we know” despite the court’s instruction to avoid it, leading the defendant to object multiple times. The court sustained the objections but did not declare a mistrial.On appeal, the Maine Supreme Judicial Court reviewed the trial court’s decisions. It held that the change log was not automatically discoverable under Maine Rule of Unified Criminal Procedure 16(a)(2) and was not material or relevant to the defense under Rule 16(c). The court further concluded that permitting the recall of the witness to clarify ambiguous testimony did not constitute an abuse of discretion. Finally, the court found that the prosecutor’s improper comments during closing did not amount to obvious error requiring a mistrial, as the trial court sustained objections and issued curative instructions. The judgment of conviction was affirmed. View "State of Maine v. Burns" on Justia Law

Desroisiers was stopped by police while driving a Chevrolet Trailblazer with her mother as a passenger. The vehicle lacked an inspection sticker, prompting a police sergeant to initiate a traffic stop. The vehicle was registered but not to Desroisiers, who was on pre-conviction bail requiring her to commit no criminal act. During the encounter, Desroisiers resisted requests for documentation, accused the officer of harassment, and refused to comply with commands to be handcuffed. She crossed her arms, attempted to pull away, dropped to the ground after being handcuffed, and later stuck her foot outside the cruiser door, requiring officers to push it in. Footage showed her thrashing inside the cruiser.The Aroostook County Superior Court held a jury trial and admitted relevant evidence, including body camera footage. Desroisiers moved for judgments of acquittal on the charge of refusing to submit to arrest or detention, arguing the evidence showed only passive resistance, not physical force. The court denied the motions. The jury convicted her of refusing to submit to arrest or detention by using physical force against a law enforcement officer, operating an unregistered vehicle, and violating a condition of release. Desroisiers subsequently renewed her acquittal motions, which were again denied, and she timely appealed.The Maine Supreme Judicial Court reviewed the case. It interpreted the statutory phrase “uses physical force against a law enforcement officer” to include any muscular effort directed toward an officer’s attempt to detain, not just violent or injurious acts. The court held that Desroisiers’s crossing her arms, pulling away, and obstructing the cruiser door constituted physical force under the statute, affirming her convictions for refusing to submit to arrest and violating a condition of release. However, the court found insufficient evidence that Desroisiers was the current owner required to register the vehicle, vacating her conviction for operating an unregistered vehicle. View "State of Maine v. Desrosiers" on Justia Law

Berwick Solar, LLC entered into an interconnection agreement with Central Maine Power Company (CMP) in March 2020 to connect its solar generation facility to CMP’s electric distribution system. The agreement estimated costs, but Berwick Solar opted not to obtain a detailed facilities study. After the project became operational in May 2021, CMP failed to issue cost reconciliation statements within the deadlines set by both the governing regulation and the agreement. CMP eventually sent a series of reconciliation statements, each seeking progressively lower amounts, but Berwick Solar disputed their timeliness and contended that CMP was required to provide further documentation for the costs.The dispute was not resolved through informal procedures, so Berwick Solar sought formal adjudication before the Maine Public Utilities Commission. After receiving testimony and briefs, the Commission dismissed Berwick Solar’s complaint, concluding that the regulation required Berwick Solar to pay the actual interconnection costs regardless of CMP’s untimely statements. The Commission also found that CMP was not obliged to provide original purchase orders or invoices, and Berwick Solar had not been prejudiced by the delay since the costs decreased over time. The Commission further declined to address Berwick Solar’s arguments about pooled overhead costs, noting those were not central to the dispute and had resulted in reduced costs for Berwick.Upon appeal, the Maine Supreme Judicial Court affirmed the Commission’s order. The Court held that CMP’s failure to issue reconciliation statements within the prescribed sixty-day period did not relieve Berwick Solar of its obligation to pay actual interconnection costs, including pooled overhead costs. CMP is not required to provide purchase orders or invoices unless requested through formal discovery. The Court also found competent evidence supporting the Commission’s finding that Berwick Solar was not prejudiced by the delay. Judgment was affirmed. View "Berwick Solar, LLC v. Public Utilities Commission" on Justia Law

In this case, a man was charged after two sisters, aged thirteen or fourteen and sixteen, reported that he engaged in various sexually inappropriate acts during the summer of 2023. The younger sister alleged that, while she was asleep at the man’s home after a family barbecue, he touched her in a sexual manner and exposed himself. The man was also accused of exposing himself and masturbating in front of both sisters by the river and showing them sexually explicit images and videos. The younger sister did not voluntarily remain at his home, was partially asleep during the incident, and did not consent to the touching. The sisters testified that they ignored his prior inappropriate behavior.The State charged the man with six offenses, including two counts of unlawful sexual touching and four counts of indecent conduct. During trial in the Piscataquis County trial court, the State disclosed sexually explicit images from the defendant’s phone late, just before the man was expected to testify. The court permitted the State to use these images for impeachment purposes if the man testified, denying his motion to exclude them as a discovery sanction. At trial’s end, the jury convicted him of unlawful sexual touching of the younger sister and two merged counts of indecent conduct but could not reach a verdict on the charge related to the older sister, which was then dismissed.The Maine Supreme Judicial Court reviewed the conviction and the trial court’s handling of the late-disclosed evidence. The Court held that sufficient evidence supported the unlawful sexual touching conviction, including the lack of the younger sister’s acquiescence and the defendant’s criminal negligence regarding her lack of acquiescence. The Court also held that the trial court did not abuse its discretion by allowing the State to use the late-disclosed evidence for impeachment only. The judgment was affirmed, except for a clerical error in the judgment and commitment, which was remanded for correction. View "State of Maine v. Bradbury" on Justia Law

On October 1, 2021, Heather Marichal was involved in a car accident in Auburn, Maine, after driving on the wrong side of the road and crashing into another vehicle, then striking a snowplow. Marichal admitted to an officer that she had consumed alcohol at a brew fest and was the sole driver. She submitted to an Intoxilyzer test that showed a blood-alcohol content of .21 grams per 210 liters of breath. Marichal was charged with criminal operating under the influence (OUI), a Class D offense.The Androscoggin County Unified Criminal Docket handled the case, with multiple continuances throughout 2022, 2023, and 2024. Marichal sought to secure the appearance of a defense witness who allegedly would testify that someone else was driving. She served a subpoena and moved for a writ of capias ad respondendum when the witness ignored the subpoena. The court issued a civil warrant for the witness, but he did not appear for the December 2024 trial. Marichal filed motions in limine to admit hearsay statements from the witness and requested another arrest warrant. The trial court denied both the motion to continue and the motion in limine, finding Marichal had not demonstrated due diligence or likelihood of securing the witness, and that the hearsay exception was not met.The Maine Supreme Judicial Court reviewed the appeal following Marichal’s conditional guilty plea. The Court held that the trial court did not abuse its discretion in denying the motion to continue, as Marichal had not shown due diligence in securing the witness nor a likelihood that a continuance would procure the witness’s attendance. The Court also determined that Marichal’s constitutional rights to compulsory process and due process were not violated, as the witness’s absence was not attributable to State action or omission. The judgment of conviction was affirmed. View "State of Maine v. Marichal" on Justia Law

An individual was charged with robbery and violation of a condition of release following an incident at a convenience store in Lewiston, Maine, on November 11, 2024. The suspect, wearing a medical mask and black Nike shoes with white trim, threatened two store clerks with a box cutter and demanded cash. Days after the robbery, police encountered the defendant and observed that he possessed shoes and a box cutter matching items used in the crime. The prosecution sought to introduce evidence of a similar attempted robbery at a nearby 7-Eleven on November 14, which also involved a masked individual with black and white shoes and a black and red box cutter, although the defendant was not charged with that offense.The State charged the defendant in the Androscoggin County Unified Criminal Docket. Before trial, the prosecution notified the court of its intent to introduce evidence of the uncharged 7-Eleven robbery to establish the defendant’s identity as the perpetrator of the charged robbery. The defendant moved to exclude this evidence under Maine Rules of Evidence 404(b) and 403. The trial court allowed the evidence, finding it probative and not unfairly prejudicial. During the jury trial, video and photographic evidence from both robberies were shown. The jury convicted the defendant of robbery, and the court found him guilty of violating his release conditions. He was sentenced to concurrent terms of imprisonment and appealed both his conviction and sentence.The Supreme Judicial Court of Maine held that the trial court erred in admitting evidence of the uncharged 7-Eleven robbery because the State did not present separate or additional evidence identifying the defendant as the perpetrator of that crime. The error was not harmless, as it could have improperly influenced the jury. Accordingly, the Court vacated the judgment of conviction and remanded the case for further proceedings. View "State of Maine v. Footman" on Justia Law

The defendant was charged with numerous offenses stemming from a series of violent incidents against a single victim, with whom he had a romantic relationship. Over several months, the defendant repeatedly assaulted the victim, causing severe injuries including facial fractures, organ damage, and psychological trauma. The assaults occurred at different locations and were witnessed or reported to various individuals, including family members and law enforcement. The victim sometimes gave inconsistent explanations for her injuries, initially attributing them to accidents or assaults by others, but later testified that the defendant was the perpetrator.The charges were brought in Androscoggin and Franklin Counties and included kidnapping, domestic violence elevated aggravated assault, aggravated assault, stalking, criminal threatening, and violations of conditions of release. After joinder, the case was tried to a jury in Androscoggin County. The defendant denied the assaults and presented an alibi, supported by family testimony. The jury found him guilty of most charges, acquitting him of kidnapping and one count of elevated aggravated assault, but convicting on a lesser-included offense and other counts. The trial court merged certain convictions as required by double jeopardy principles and imposed a primary sentence of twenty-eight years, with concurrent sentences on the remaining counts.On appeal to the Maine Supreme Judicial Court, the defendant challenged the exclusion of impeachment evidence regarding the victim’s prior inconsistent statements, the admission of evidence of earlier assaults, and the sentencing process. The court held that although the impeachment evidence should have been admitted, the exclusion was ultimately harmless given the substantial corroboration of the victim’s account and her impeachment by other means. The court found no error in admitting evidence of prior assaults or in the sentencing analysis. All convictions and the sentence were affirmed. View "State of Maine v. Hanson" on Justia Law

The case involves two parents, Emily A. Bickford and Matthew A. Bradeen, who share parental rights and responsibilities for their child. They initially agreed to a shared parenting arrangement in 2013, requiring joint decisions on matters such as the child’s religious upbringing and medical care. In 2021, disputes arose when Bradeen alleged that Bickford involved the child in religious activities without his knowledge, while Bickford claimed Bradeen tried to prevent the child’s religious training. Both parents sought sole authority over the child’s religious upbringing. After mediation resolved most issues except religion and healthcare, the District Court held hearings and found that Bickford's unilateral decisions regarding religion and medical care caused the child anxiety and endangered her relationship with Bradeen. The court also found that Bradeen was more capable of making decisions in the child’s best interest.The District Court (Portland) modified the prior order, allocating to Bradeen final decision-making authority regarding the child’s religious upbringing (especially relating to Calvary Chapel Greater Portland) and medical care. The court used a best-interest standard for medical decisions and, believing strict scrutiny was required for religious matters, found a compelling interest in protecting the child from psychological harm. Bickford’s motions for post-judgment relief were denied, and she appealed, arguing constitutional violations.The Maine Supreme Judicial Court reviewed the case and clarified that strict scrutiny does not apply to allocations of parental rights between parents, even in religious matters. The Court held that the best-interest standard governs such decisions, provided there is no religious bias. It found no evidence of religious hostility or abuse of discretion by the District Court and affirmed the judgment, upholding Bradeen’s final authority in the disputed areas. View "Bickford v. Bradeen" on Justia Law

A minor covered by MaineCare sustained an arm and elbow injury requiring medical treatment, for which MaineCare paid $34,078.70, though providers billed much more. The minor’s mother sued two third-party tortfeasors, seeking $375,000 in damages, including over $200,000 in medical bills. The claim was settled for $160,000, less than half the original claimed value. The Department of Health and Human Services asserted a lien for the full amount it paid. The mother filed suit against the Department, arguing that the Department’s recovery should be limited to the proportion of the settlement attributable to medical expenses, using a formula derived from Arkansas Department of Health and Human Services v. Ahlborn, 547 U.S. 268 (2006).The Androscoggin County Superior Court entered summary judgment for the plaintiff, applying the percentage of total damages recovered (42.67%) to the amount the Department paid, thereby reducing the Department’s recovery to $14,540.25. The Department appealed, arguing that the calculation should be based on the entire amount billed for medical expenses, not the amount paid, and that the allocation formula was not appropriate without further factual findings.The Maine Supreme Judicial Court reviewed the case and vacated the judgment. The court held that, when a settlement does not allocate amounts between medical expenses and other damages and the parties do not stipulate to an allocation, the trial court must conduct an individualized, fact-intensive evidentiary hearing to determine what portion of the settlement is reasonably attributable to medical expenses. Only that portion is available for the Department’s recovery, limited to the amount it actually paid. The court rejected the use of a rigid formula or arbitrary reduction and remanded for further proceedings. View "Lynne v. Department of Health and Human Services" on Justia Law

James Welsh resided in a Bangor apartment building in which multiple tenants accessed their residences through a shared hallway. On January 20, 2024, Welsh’s neighbor saw him standing naked in the shared hallway outside her apartment. Disturbed by the incident, she contacted the police. When a responding officer arrived, he observed Welsh naked inside his own apartment, with the door to the hallway open. Welsh was given a summons for indecent conduct, and it was established that he had two prior convictions for the same offense.The case proceeded to a bench trial in the Penobscot County Unified Criminal Docket, where the prosecution presented testimony from the neighbor and the police officer, as well as documentary evidence of Welsh’s prior convictions. Welsh argued that the State failed to prove that his conduct occurred in a “public place,” as required by the Maine indecent conduct statute. The trial court denied Welsh’s motion for acquittal, reasoning that the shared hallway was a public place. However, at the conclusion of the trial, the court based its finding of guilt not on Welsh’s conduct in the hallway, but on his exposure while standing naked inside his apartment with the door open, specifically during the interaction with the police officer.Upon review, the Maine Supreme Judicial Court determined that the trial court erred in treating Welsh’s apartment as a public place under the statute. The Law Court clarified that a “public place” for the purposes of Maine’s indecent conduct statute includes shared hallways accessible to others, but not an individual’s private apartment. Although there was evidence Welsh was naked in the public hallway, the trial court had not made findings on that basis. The Law Court vacated Welsh’s conviction and remanded the case for the trial court to make appropriate findings regarding his conduct in the shared hallway and to apply the correct statutory interpretation. View "State of Maine v. Welsh" on Justia Law