Justia Maine Supreme Court Opinion Summaries

The case involves the conviction of a defendant for murder following the stabbing death of Kimberly Neptune, who was found in her apartment with 484 sharp force injuries. The defendant, Kailie Brackett, and a co-defendant, Donnell Dana, Jr., were indicted for intentional, knowing, or depraved indifference murder. The prosecution presented evidence including surveillance footage, testimony from witnesses about Brackett’s relationship with the victim and usage of the victim’s bank card, as well as forensic evidence from the crime scene. Notably, the prosecution relied on expert testimony comparing partial, sock-clad bloody footprints found at the scene to prints taken from Brackett in prison.The Washington County Unified Criminal Docket conducted the jury trial. Brackett objected to the admission of the forensic podiatry evidence, arguing it lacked scientific reliability. The trial court admitted the expert testimony over her objections, and the jury ultimately found Brackett guilty, but deadlocked as to Dana. Brackett was sentenced to fifty-five years in prison and appealed her conviction and sentence, challenging the sufficiency of the evidence, admission of the expert testimony, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court erred in admitting the forensic podiatry testimony comparing the partial, sock-clad footprints. The expert’s methodology lacked scientific reliability and was not sufficiently grounded in recognized standards, and the prosecutor’s closing arguments improperly characterized this evidence as definitive proof of Brackett’s presence at the scene. Because this error was likely to have affected the jury’s verdict, the Court vacated Brackett’s conviction and remanded for a new trial, holding that the State may retry Brackett but must exclude the challenged footprint comparison testimony. View "State of Maine v. Brackett" on Justia Law

Aaron Aldrich was convicted of two counts of intentional or knowing murder and possession of a firearm by a prohibited person. The evidence at trial showed that Aldrich went to a trailer in Poland, Maine, carrying a nine-millimeter rifle. He entered the trailer, shot both an adult and a teenager multiple times, and took a handgun and cash before leaving. Afterward, Aldrich told his friend he had killed the residents and instructed his girlfriend to dispose of evidence. The police later found forensic evidence linking Aldrich to the crime scene and recovered the murder weapon. He was apprehended in New Hampshire after fleeing in a stolen van.The Androscoggin County Unified Criminal Docket conducted a jury trial. Aldrich moved to suppress his post-arrest statements, claiming Miranda violations and improper questioning after requesting counsel; this motion was denied after an evidentiary hearing. The trial court made several evidentiary rulings, including admitting images of the victims, evidence of Aldrich’s theft and flight, testimony about his prior acts, and limiting cross-examination of witnesses. Aldrich testified, claiming self-defense. The jury found him guilty on all counts. He was sentenced to concurrent life terms for the murder convictions and five years for the firearm-possession count. Aldrich appealed both his convictions and sentences, arguing errors in suppression, evidentiary rulings, jury instructions, and sentencing analysis.The Maine Supreme Judicial Court reviewed all claims. The court held that the denial of the motion to suppress was correct because Aldrich was not subjected to custodial interrogation under Miranda. Most evidentiary rulings were proper; the few errors identified, including admission of hearsay and exclusion of certain defense evidence, were harmless and did not cumulatively deprive Aldrich of a fair trial. The jury instructions and sentencing analysis were found to be legally sound. The court affirmed the convictions and sentences. View "State of Maine v. Aldrich" on Justia Law

In 1996, a series of crimes including gross sexual assault and burglary were committed in Hancock County, Maine. The State filed a criminal complaint in August 2002, just before the statute of limitations was set to expire, naming the accused as “John Doe #1, Unknown Male with Matching Deoxyribonucleic Acid (DNA) Profile at 13 Genetic Locations.” An arrest warrant based on the DNA profile was issued. For the next twenty years, advancements in forensic genetic genealogy eventually enabled law enforcement to identify Jason J. Follette as the suspect. In November 2022, the State amended the complaint to specifically name Follette and charged him with the same offenses. Follette was arrested, appeared in court, and was released on bail.The case was reviewed by the Maine District Court in Hancock County. Follette filed several pretrial motions, including the motion to dismiss at issue here, arguing that (1) the State’s prosecution was barred because he was not specifically named in the initial complaint within the statute of limitations, and (2) the lengthy delay violated his Sixth Amendment right to a speedy trial. After a hearing, the court denied the motion, finding that the 2002 complaint tolled the statute of limitations and that his speedy trial rights were not violated.On appeal, the Maine Supreme Judicial Court considered Follette’s arguments but ultimately concluded that the appeal was interlocutory, as it sought review of a pretrial order denying a motion to dismiss. The court determined that none of the recognized exceptions to Maine’s final judgment rule applied, including the judicial economy, death knell, or collateral order exceptions. As a result, the court dismissed the appeal for lack of a final judgment, holding that review of the statute of limitations and speedy trial claims must await final resolution of the case. View "State of Maine v. Follette" on Justia Law

A solar energy developer sought to build a facility in Maine with an initial capacity of 4.98 megawatts, later reduced to 1.99 megawatts after changes to state law. The developer submitted an interconnection application to the local utility, obtained necessary permits, made payments, and began construction. During the project’s development, delays occurred in procuring key equipment, such as the meter and voltage regulator, resulting in a projected completion date after the statutory deadline of December 31, 2024. Despite the developer’s efforts, the facility was not operational by the required date.The developer petitioned the Maine Public Utilities Commission for a good cause exemption from the Commercial Operation Date deadline under Maine’s Net Energy Billing statute. After discovery and intervention by the Office of the Public Advocate, a Commission staff report recommended granting the exemption. However, the Commission ultimately denied the exemption, finding insufficient evidence that the developer ever received an initial construction schedule projecting completion within the 2024 deadline. The developer subsequently petitioned to reopen the record to submit additional evidence, but the Commission did not act on the petition within the required timeframe, resulting in a deemed denial. The developer appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court affirmed the Commission’s orders. The Court held that the Commission’s factual finding—that the developer failed to prove receipt of an initial schedule with a timely completion date—was supported by substantial evidence. The Court also found the Commission’s interpretation of the statute reasonable, its decision not arbitrary, and its refusal to reopen the record not an abuse of discretion. The judgment of the Commission was affirmed. View "Ellsworth ME Solar, LLC v. Public Utilities Comission" on Justia Law

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