Justia Maine Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of assault on an officer and criminal mischief. Appellant appealed, arguing that his trial counsel provided ineffective assistance by electing not to make an opening statement, not cross-examining the State’s witnesses, not presenting any evidence for the defense, and presenting only a brief closing argument. The Supreme Court affirmed, holding that the issues Appellant raised regarding ineffective assistance of counsel were not properly raised on direct appeal and instead must be addressed in a fact-finding proceeding to determine if trial counsel’s action resulted from incompetence, appropriate strategic choices, or other considerations. View "State v. Troy" on Justia Law

John and Jane Doe, the parents Susan Doe, a transgender girl, filed a complaint with the Maine Human Rights Commission alleging that Regional School Unit 26 (RSU 26) had violated the Maine Human Rights Act (MHRA) by excluding Susan from the communal girls’ bathroom at elementary and middle school. The Commission found reasonable grounds to believe discrimination had occurred. Thereafter, the Does and the Commission filed a complaint in the superior court asserting claims for unlawful discrimination in education (Count I) and unlawful discrimination in a place of public accommodation (Count II) on the basis of sexual orientation. The superior court granted RSU 26’s motion for summary judgment on all counts. The Supreme Court vacated the judgment of the superior court, holding that where it has been clearly established that a student’s psychological well-being and educational success depend on being permitted to use the communal bathroom consistent with her gender identity, denying the student access to the appropriate bathroom constitutes sexual orientation discrimination in violation of the MHRA. Remanded for entry of summary judgment for the Does and the Commission. View "Doe v. Reg'l Sch. Unit 26" on Justia Law

Plaintiff was a public assistance recipient who was accepted to rent an apartment owned by RRE Coach Lantern Holdings, LLC. Plaintiff’s caseworker indicated that Coach Lantern would have to include a Housing and Urban Development (HUD) tenancy addendum in Plaintiff’s lease for Plaintiff to be able to use her voucher for subsidized rent. Coach Lantern refused to include the addendum in Plaintiff’s lease. Because Plaintiff could not use the voucher unless Coach Lantern included the addendum in her lease, Plaintiff did not rent the apartment. Plaintiff subsequently filed a complaint with the Maine Human Rights Commission alleging that Coach Lantern’s policy of refusing to include the HUD tenancy addendum in her lease constituted a refusal to participate in the voucher program, which amounted to discrimination against Plaintiff on the basis of her status as a public assistance recipient in violation of the Maine Human Rights Act (MHRA). The superior court entered summary judgment in favor of Coach Lantern. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Coach Lantern because the undisputed facts showed that Coach Lantern did not discriminate against Plaintiff in violation of the MHRA. View "Dussault v. RRE Coach Lantern Holdings, LLC" on Justia Law

After a jury trial, Defendant was found guilty of two counts of aggravated trafficking of a schedule W drug within one thousand feet of a school and of twice violating the conditions of his release in a related case. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant subsequently filed a petition for post-conviction review, asserting that he received ineffective assistance of counsel by failing to conduct a reasonable investigation to discover three recent pending criminal matters against a key witness and in failing to impeach the credibility of the witness on that basis. The post-conviction court denied relief. The Supreme Court affirmed, holding (1) the record supported the court's finding that defense counsel provided effective assistance regarding the witness' second and third criminal matters; and (2) the court did not err in concluding that discovering and impeaching the witness on the first criminal matter likely would not have affected the outcome of the trial. View "Lamarre v. State" on Justia Law

Defendant was indicted on charges of burglary and theft. Defendant filed a motion to suppress the evidence obtained pursuant to three search warrants for Defendant's house, garage, and car. The superior court granted the motion to suppress, concluding that the first affidavit did not establish probable cause for a search and that the evidence seized pursuant to the third search warrant, which allowed officers to search Defendant's house again after the initial search, must be suppressed as fruit of the poisonous tree. The Supreme Court affirmed the suppression of the evidence obtained in the three searches, holding (1) the first affidavit provided an insufficient basis for a finding of probable cause; (2) the officers' reliance on the warrants was not objectively reasonable; and (3) because the third warrant relied heavily on observations officers made while executing the first warrant, the evidence seized pursuant to that warrant must also be suppressed. View "State v. Johndro" on Justia Law

Berwick Iron & Metal Recycling, Inc. operated a metal and automobile recycling business under an existing conditional use permit. In 2010, Berwick Iron applied for a conditional use permit to install and operate a metal shredder. On remand, the Berwick Planning Board voted to approve the conditional use permit. The superior court vacated the Board's judgment, concluding that the Board erred in applying the ordinance governing air emissions. Both parties appealed. On cross-appeal, the abutters argued, among other things, that the superior court erred in concluding that the Board did not violate the abutters' due process rights by communicating ex parte with representatives from Berwick Iron. The Supreme Court vacated the superior court's judgment and remanded for entry of a judgment affirming the Board's decision, holding that, despite the Board's ex parte communications with Berwick Iron, the Board did not violate the abutters' due process rights or err in applying its ordinance. View "Duffy v. Town of Berwick" on Justia Law

This case involved three Enhanced 9-1-1 (E-9-1-1) calls regarding an altercation that resulted in three people being shot. MaineToday Media, Inc. sent a series of requests to inspect and copy the three transcripts to the police department, state police, attorney general, and others. The State denied the requests, claiming that the transcripts constituted "intelligence and investigative information" in a pending criminal matter and were therefore confidential under the Criminal History Record Information Act. MaineToday filed suit against the State, arguing that the Freedom of Access Act (FOAA) mandated disclosure of the transcripts as public records and that no exception to their disclosure applied. The superior court affirmed the State's denial of MaineToday's request. The Supreme Court vacated the lower court's judgment, holding that the E-9-1-1 transcripts, as redacted pursuant to 25 Me. Rev. Stat. 2929(2)-(3), were public records subject to disclosure under the FOAA. View "MaineToday Media, Inc. v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault, criminal threatening with a dangerous weapon, criminal restraint, and violation of a condition of release. The Supreme Court affirmed, holding (1) the trial court did not err in admitting evidence related to the events that preceded Defendant's arrest; (2) the trial court did not err in admitting testimony regarding the methods the police used to compile a photographic array that was shown to the victim; and (3) the prosecutor did not commit misconduct by improperly vouching for the victim's credibility during closing argument because, viewed in context, the prosecutor's statement was not witness-vouching or otherwise improper. View "State v. Hassan" on Justia Law

After a jury trial, Defendant was convicted of aggravated attempted murder, aggravated criminal mischief, reckless conduct with a dangerous weapon, eluding an officer, and theft by unauthorized taking or transfer. Defendant appealed, arguing (1) the trial court erred when it failed, sua sponte, to instruct the jury on self-defense and voluntary intoxication, and (2) the trial court erred when it did not conduct a colloquy directly with him to confirm he knowingly and voluntarily chose not to testify. The Supreme Court affirmed, holding (1) Defendant waived jury instructions on self-defense and intoxication, and therefore, the trial court did not commit obvious error by not instructing on those defenses; and (2) Defendant waived his right to testify, and therefore, the trial court committed no error here by confirming the election not to testify through counsel. View "State v. Ford" on Justia Law

Defendant, who was eighteen years old at the time, was badly injured in a single-vehicle accident. While she lay sedated at the hospital, a police trooper, without providing Miranda warnings, questioned Defendant about the car accident, seeking information as to who was driving. After a pause in the questioning, the trooper told Defendant that two of her friends who had been in the car were dead and urged Defendant to tell the truth about who was driving. Defendant subsequently made inculpatory statements. Defendant was indicted on two counts of manslaughter, two counts of aggravated criminal OUI, and one count of leaving the scene of an accident that resulted in serious bodily injury. The trial court granted Defendant's motion to suppress as to all statements Defendant made after the pause in the interview, concluding (1) at that point, Defendant became a suspect and was in custody because she reasonably did not believe that she was free to terminate the interview; and (2) consequently, Defendant should have been given Miranda warnings. The Supreme Court affirmed, holding that the district court did not err in finding that Defendant's statements throughout were voluntary but that Defendant was in custody after the break in the interview. View "State v. Lowe" on Justia Law