Justia Maine Supreme Court Opinion Summaries

A District Court in Caribou, Maine, issued a judgment in February 2024 regarding the parental rights and responsibilities of a child born to Andrew M. Landeen and Ashley Burch, who were former romantic partners but never married. The court granted primary physical residence to Burch and visitation rights to Landeen. Additionally, the court changed the child's last name to "Landeen" without providing specific findings or comments on the decision. Burch appealed the name change, and Landeen cross-appealed the allocation of parental rights and responsibilities.The District Court's judgment was based on the best interest of the child, considering factors such as the parents' ability to cooperate and the child's emotional and physical safety. The court found that Landeen's persistent anger towards Burch and his inability to manage frustration appropriately were detrimental to the child's best interest. Consequently, the court allocated primary parental rights to Burch while allowing Landeen visitation rights and the right to be informed of major decisions concerning the child.The Maine Supreme Judicial Court reviewed the case and found that the District Court's allocation of parental rights and responsibilities was supported by the record and did not constitute an abuse of discretion. However, the Supreme Judicial Court vacated the portion of the judgment changing the child's last name. The court held that the father’s desire to change the child's surname, based solely on tradition and without supporting evidence, did not meet the statutory requirement of showing "good cause" or that the change was in the child's best interest. The court emphasized that both parents have equal rights in naming their child and that any name change must be justified by the child's best interest. View "Landeen v. Burch" on Justia Law

Billy L. Beaulieu was charged with criminal OUI (Class C) under Maine law. He filed a motion to dismiss the charges, claiming immunity under Maine’s Good Samaritan statute, which provides immunity from prosecution if a call for assistance for a suspected drug-related overdose is made at the location of a medical emergency. Beaulieu argued that the statute’s requirements were met because a driver who saw his car beside an interstate highway exit asked the police to check on the vehicle, suspecting a medical event.The Cumberland County trial court denied Beaulieu’s motion to dismiss. The court found that the witness was concerned about a medical event and reported it to the police, who then checked on Beaulieu. However, the court concluded that the situation did not meet the statutory requirements for immunity because the call was not for a suspected drug-related overdose, and there was no medical emergency.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the Good Samaritan statute’s plain language requires the call for assistance to be specifically for a suspected drug-related overdose and that the location must be a medical emergency. The court found that the witness’s concern about a general medical event did not satisfy the statute’s requirements. Additionally, there was no evidence of a medical emergency at the scene. Therefore, Beaulieu was not entitled to immunity under the Good Samaritan statute, and the denial of his motion to dismiss was affirmed. View "State of Maine v. Beaulieu" on Justia Law

Dennis W. Lowery was convicted of gross sexual assault after a jury trial in Cumberland County. The incident occurred on December 19, 2021, when Lowery entered the victim's room at a Portland inn without her knowledge or permission and sexually assaulted her while she was asleep. The victim identified Lowery to the police, who found him nearby. DNA evidence linked Lowery to the crime.The trial court denied Lowery's motions to dismiss and for a new trial, which were based on alleged discovery violations by the State. Lowery argued that the State failed to disclose information about certain witnesses and evidence handlers in a timely manner. The court allowed the testimony of these witnesses, reasoning that Lowery was aware of their roles and had the opportunity to cross-examine them. The court also denied Lowery's motion for a judgment of acquittal on the gross sexual assault charge but granted it on a burglary charge due to a defect in the indictment.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decisions. The court held that the trial court did not abuse its discretion in handling the alleged discovery violations, as Lowery was not prejudiced to the extent that it deprived him of a fair trial. The court also found no obvious error in the admission of evidence regarding Lowery's pre-arrest silence, as Lowery did not invoke his right to remain silent before being questioned by the police. The court concluded that the trial court's actions were appropriate and did not violate Lowery's due process rights. View "State of Maine v. Lowery" on Justia Law

The case involves a dispute over a 1944 deed that placed a 330-acre parcel of land, known as Camp Bomazeen, in a charitable trust for use by the Boy Scouts of America for camping. Pine Tree Council, Inc., Boy Scouts of America (Pine Tree) appealed a summary judgment from the Superior Court (Kennebec County) against it on the Attorney General’s complaint for breach of trust and on Pine Tree’s counterclaims for declaratory judgment regarding its property rights in the land. Intervenors Bruce F. Rueger and Scott F. Adams, representing the Bomazeen Old Timers, cross-appealed, arguing the court erred in entering summary judgment against them on their claims against Pine Tree for breach of fiduciary duties and their request for the court to apply the cy pres doctrine.The Superior Court found in favor of the Attorney General, concluding that Pine Tree had only legal title to the property and not equitable title. The court determined that Pine Tree could sell Camp Bomazeen but must use the proceeds to support camping activities for Boy Scouts in central Maine, consistent with the trust’s purposes. The court also ruled against Pine Tree on its counterclaims and against the Old Timers on their claims.The Maine Supreme Judicial Court affirmed the Superior Court’s judgment. It held that Pine Tree succeeded only to legal title of the property and not to equitable title, meaning the trust did not terminate. The court also held that the proceeds from any sale of Camp Bomazeen must be used for the trust’s original purposes. The court found no basis for applying the cy pres doctrine, as the trust’s purposes could still be achieved. The judgment against Pine Tree and the Old Timers was affirmed. View "Attorney General v. Pine Tree Council, Inc., Boy Scouts of America" on Justia Law

Richard W. Kelley was convicted of aggravated trafficking of scheduled drugs after a stop and search of a friend's vehicle in which he was a passenger. Law enforcement conducted the search as part of an investigation into the vehicle's owner for drug trafficking, using a search warrant and two tracking warrants to monitor the vehicle's location. Kelley moved to suppress the evidence obtained through the warrants, arguing that he had a reasonable expectation of privacy in the vehicle.The trial court (Penobscot County, A. Murray, J.) denied Kelley's motion to suppress on the grounds that he lacked standing to challenge the search. Kelley argued that the court should not have reached the question of his standing because the State had stipulated that he had a reasonable expectation of privacy in the vehicle. However, the court concluded that standing is a threshold issue that must be addressed, and Kelley did not have a reasonable expectation of privacy in the vehicle.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the State's stipulation regarding Kelley's standing was not binding on the court and that Kelley lacked a reasonable expectation of privacy in the vehicle. The court noted that Kelley did not own the vehicle, had never driven it, and had only stored personal items in it for a short period. Therefore, Kelley did not have standing to challenge the search warrants, and the judgment of conviction was affirmed. View "State of Maine v. Kelley" on Justia Law

Ramel L. Sheppard was convicted of domestic violence aggravated assault after a jury trial in which the victim did not testify. The conviction was based in part on the victim's hearsay statement to a police officer identifying Sheppard as her attacker. Sheppard appealed, arguing that the trial court erred in admitting the hearsay statement as an excited utterance and that its admission violated his rights under the Confrontation Clause of the U.S. Constitution.The trial court (Androscoggin County) admitted the victim's statement under the excited utterance exception to the hearsay rule, finding that the statement was made spontaneously and while the victim was still under the stress of the assault. The court also determined that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. The jury found Sheppard guilty on two counts, but the court later merged one count into the other and sentenced Sheppard to seven years' imprisonment, with all but forty months suspended, and three years of probation.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that the trial court did not abuse its discretion in admitting the victim's statement as an excited utterance, as the statement was made spontaneously and under the stress of the assault. The court also held that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. Therefore, the admission of the statement did not violate Sheppard's rights under the Confrontation Clause. View "State of Maine v. Sheppard" on Justia Law

Between 2007 and 2009, Susan McCarthy’s minor child, M, was in the care of McCarthy’s friend, Glynis McCormack, at McCormack’s home. During this time, McCormack’s minor nephew, Z, who also lived there, physically, sexually, and emotionally abused M, resulting in ongoing mental health issues for M. McCormack was insured under a homeowner’s policy issued by Metropolitan Property and Casualty Insurance Company. McCarthy obtained a consent judgment against McCormack, agreeing to recover a limited amount directly from McCormack and seek the remainder from Metropolitan as McCormack’s insurer.The Superior Court (York County) declared that Metropolitan had no duty to indemnify McCormack for the consent judgment. McCarthy appealed this declaratory judgment. Previously, Metropolitan had filed a complaint for declaratory judgment in the United States District Court, asserting no duty to defend or indemnify McCormack due to policy exclusions. The District Court declared Metropolitan had a duty to defend McCormack but could not litigate its duty to indemnify until McCormack’s liability was determined. The First Circuit affirmed this decision. Subsequently, McCarthy and McCormack settled, and the Superior Court entered a consent judgment.The Maine Supreme Judicial Court reviewed the case and affirmed the Superior Court’s judgment. The court held that the “intentional loss” and “abuse” exclusions in McCormack’s policy barred coverage for McCarthy’s claims. The court concluded that both McCormack and Z fell within the policy definition of “you,” and thus, Z’s intentional acts of abuse, which were excluded from coverage, also excluded McCormack from coverage. Consequently, Metropolitan had no duty to indemnify McCormack for the consent judgment. View "Metropolitan Property and Casualty Insurance Company v. McCarthy" on Justia Law

Campbell and Jennie Clegg purchased first-class round-trip tickets from American Airlines for themselves and three family members for travel between Albany, New York, and San Francisco, California, in May 2022. They agreed to American’s Conditions of Carriage, which required check-in at least 45 minutes before departure. The night before their flight, the Cleggs were unable to check in online and were instructed to check in at the airport. They arrived at the airport at 4:47 a.m. for their 6:04 a.m. flight but were unable to check in due to a computer system issue. Consequently, they missed their flight and later found that their return flight was canceled. They did not receive a refund for either flight.The Cleggs filed a complaint in the Cumberland County Superior Court, alleging breach of contract, fraud, and breach of the Maine Unfair Trade Practices Act. The court granted American Airlines' motion for summary judgment, ruling that the Cleggs’ claims were preempted by the Airline Deregulation Act. The Cleggs appealed the decision.The Maine Supreme Judicial Court reviewed the case and vacated the Superior Court's judgment in part. The court held that while the Airline Deregulation Act preempts state law claims related to airline services, the Cleggs could pursue a breach of contract claim based on the Conditions of Carriage. The court determined that the Cleggs might be entitled to a refund for their tickets and any extras, as specified in the Conditions of Carriage. However, the court affirmed that the Cleggs could not recover consequential or punitive damages, attorney fees, or costs, as these were preempted by the Airline Deregulation Act. The case was remanded for further proceedings consistent with this opinion. View "Clegg v. American Airlines, Inc." on Justia Law

The case involves a dispute between the Government Oversight Committee of the 131st Maine Legislature and the Maine Department of Health and Human Services (DHHS) over access to confidential records related to the deaths of four children in 2021. The DHHS refused to provide the records, citing confidentiality laws. The Committee then filed an action in the Superior Court (Kennebec County) to compel the DHHS to comply with its subpoena. The Superior Court denied the Committee’s request, and the Committee appealed.The Superior Court (Kennebec County) ruled that the Committee did not have the statutory authority to access the confidential records and denied the motion to compel. The Committee then appealed the decision to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court affirmed the Superior Court’s judgment. The Court held that the Committee does not have the statutory authority to access confidential records under the OPEGA statute, which limits the Committee’s access to public information and records. The Court also found that the statutory exception in 22 M.R.S. § 4008(3)(D) does not apply to the Committee, as it is not considered a “legislative official with responsibility for child protection services.” Additionally, the Court rejected the Committee’s argument that it has inherent legislative power to compel the disclosure of confidential information via subpoena, as this power is limited by the Committee’s statutorily prescribed duties and the nature of the information it may receive. View "Government Oversight Committee v. Department of Health and Human Services" on Justia Law

Dylan Ketcham was convicted of the murder of Jordan Johnson, attempted murder, and elevated aggravated assault against Caleb Trudeau. The incident occurred on January 24, 2020, when Ketcham and Johnson exchanged hostile messages and agreed to meet. Trudeau accompanied Johnson, expecting a fistfight. Ketcham shot Johnson in the head and attacked Trudeau with a machete, causing severe injuries. Johnson died days later, and Trudeau survived but with lasting impairments.The State initially charged Ketcham with elevated aggravated assault and later with murder after Johnson's death. A mental examination deemed Ketcham competent for trial. A mistrial was declared in September 2022 due to prejudicial evidence. Before the new trial, the court limited the admission of certain text messages between Johnson and Trudeau. During the January 2023 trial, the court allowed some messages to be discussed but limited their use to showing the relationship and state of mind, not self-defense. The jury found Ketcham guilty on all counts.The Maine Supreme Judicial Court reviewed the case. Ketcham argued that the trial court erred in limiting the jury's consideration of the messages and in not ordering a competency evaluation during the trial. He also challenged his sentence as a misapplication of sentencing principles and an illegal de facto life sentence. The court found no abuse of discretion in the trial court's handling of the messages or in its decision not to order a competency evaluation. The court also upheld the sentences, finding them proportionate to the crimes committed and not constituting a de facto life sentence. The judgment and sentence were affirmed. View "State of Maine v. Ketcham" on Justia Law