Justia Maine Supreme Court Opinion Summaries

BAC Home Loans Servicing, LP filed a complaint for foreclosure against Scott and Kristina Greenleaf. Bank of America, N.A. (the Bank) was substituted for BAC after the entities merged. After a trial, the court entered a judgment of foreclosure in favor of the Bank. The Supreme Judicial Court vacated the judgment based on the Bank’s lack of standing. On remand, the district court dismissed without prejudice the action due to the Bank’s standing defect. Scott appealed, arguing that the court was compelled to enter judgment in his favor because the Court vacated the Bank’s judgment after a completed trial. The Supreme Judicial Court affirmed, holding that, under the circumstances of this case, the district court properly disposed of the case by entering a dismissal without prejudice. View "Bank of America, N.A. v. Greenleaf" on Justia Law

Defendant pleaded guilty in federal court to sexual exploitation of a child and possession of child pornography. Before sentencing, a state grand jury indicted Defendant on thirteen counts of gross sexual assault. Defendant pleaded not guilty to all of the gross sexual assault charges. After the federal district court sentenced Defendant, Defendant filed a motion to dismiss the State’s indictments for gross sexual assault, arguing that the State’s prosecution subjected him to double jeopardy. The trial court denied the motion to dismiss. The Supreme Judicial Court affirmed, holding (1) even if the State’s current prosecution subjects Defendant to the risk of being punished twice for the same conduct, such duplicative punishment is constitutional when, as in this case, the punishments are imposed by separate sovereigns; and (2) there is no evidence to sustain Defendant’s contention that an exception to the “dual sovereignty” doctrine of double jeopardy jurisprudence applied in this case. View "State v. Hoover" on Justia Law

After a hearing, the district court terminated Father’s parental rights pursuant to Me. Rev. Stat. 22, 4055. The Supreme Judicial Court affirmed, holding (1) the district court did not improperly terminate Father’s parental rights solely because he had been diagnosed as having borderline personality disorder and thus did not violate Father’s equal protection rights; (2) the district court provided Father with the due process required in the context of a termination of parental rights by providing him with a reasonable period of time for reunification and not improperly placing a burden of proof upon Father; and (3) there was clear and convincing evidence to support the court’s finding of at least one ground of parental unfitness and that termination was in the child’s best interest. View "In re I.S." on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

Defendant was indicted on one count of unlawfully trafficking in scheduled drugs and one count of illegal importation of scheduled drugs. Defendant filed a motion to suppress as evidence illegal drugs seized from him by law enforcement officers after they stopped a vehicle in which he was a passenger. The trial court granted the motion to suppress, concluding that the warrantless search of the clothes Defendant was wearing exceeded the bounds of a valid protective search or justifiable search for contraband. The Supreme Court vacated the suppression order, holding that the search was justified by probable cause and the existence of exigent circumstances, and therefore, the search was constitutional. Remanded. View "State v. Martin" on Justia Law

After the trial court denied Defendant’s motion to suppress evidence derived from internet service provider (ISP) records that the State obtained with a grand jury subpoena, Defendant entered a conditional guilty plea to a charge of possession of sexually explicit materials. Defendant appealed, arguing that the State was required to use the procedure set forth in Me. Rev. Stat. 5, 200-B to obtain the ISP records and that its failure to do so violated his due process rights. The Supreme Court affirmed, holding that section 200-B creates an alternative, not exclusive, method for it to use in seeking ISP records, and therefore, the trial court did not err in finding that the State was not barred from using a grand jury subpoena in obtaining the ISP records. View "State v. Bragdon" on Justia Law

After a jury trial, Defendant was convicted of the Class C charge of sexual abuse of a minor. On appeal, Defendant challenged the admission of testimony of the victim’s mother indicating when the victim told her what had happened and argued that the State committed prosecutorial misconduct in its closing arguments. The Supreme Judicial Court affirmed, holding (1) the trial court properly applied the “first complaint” rule in determining that the mother’s statement was admissible; and (2) any error in the prosecutor’s closing arguments, either individually or cumulatively, did not deprive Defendant of a fair trial. View "State v. Fahnley" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the twenty-two-year delay between the alleged assaults and the indictment. The Supreme Court affirmed, holding (1) the missing recording did not have any apparent exculpatory value at the time it was lost, and Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence, and therefore, Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the loss of the evidence; and (2) Defendant failed to meet his burden of proving that he was prejudiced by the pre-indictment delay. View "State v. Cote" on Justia Law

Marc Chamberlain was the father of two children who had been the care of their maternal grandmother for several years before and following the death of their mother. The children’s maternal grandmother and their maternal aunt petitioned the probate court for appointment as the children’s co-guardians. Chamberlain opposed the petition. The court entered a judgment appointing the grandmother, but not the aunt, as the children’s guardian. In making its decision, the court applied the plain language of Me. Rev. Stat. 18-A, 5-204(d) and found by a preponderance of the evidence that the grandmother was the children’s de facto guardian and that Chamberlain had not consistently participated in the children’s lives. Chamberlain appealed, arguing that section 5-204(d) is facially unconstitutional because it, and the statutes defining its terms, are unconstitutionally vague and violate due process. The Supreme Judicial Court vacated the judgment, holding that the appointment of a guardian over a parent’s objection upon proof by the lower standard of a preponderance of the evidence violates the Due Process Clause of the federal Constitution. Remanded for the court to apply the constitutionally required standard of proof by clear and convincing evidence when applying section 5-204(d). View "In re Guardianship of Chamberlain" on Justia Law