Justia Maine Supreme Court Opinion Summaries

In the late 1990s, Bryan Carrier pled guilty to three counts of vehicular manslaughter and three counts of aggravated operating under the influence. The judgment and commitment notified Defendant that his license was suspended for life on the manslaughter counts. In 2011, Carrier petitioned for reinstatement of his license. After a hearing, a hearing officer of the Secretary of State's Bureau of Motor Vehicles denied Carrier's petition based on the opposition of the victims' families. The superior court denied Carrier's petition for judicial review. The Supreme Court affirmed, holding that the reinstatement statute allows for consideration of the opinions of the victims and their families. View "Carrier v. Sec'y of State" on Justia Law

When Restaurant was denied a requested liquor license by the Town of Bingham, Restaurant appealed to the Department of Public Safety. After a hearing, a Department hearing officer also denied the license. On appeal, Restaurant asserted various independent claims alleging constitutional and statutory violations by the Department and Town. The appellate court found in favor of Defendants on Restaurant's independent claims but, on the merits, remanded the matter to the Department after concluding that an appeal of a municipality's denial of a liquor license could only be decided by the Commissioner of Public Safety and not a hearing officer. On remand, the Commissioner of the Department denied the license application. The Supreme Court affirmed, holding (1) the deficiencies in the Department's notice to Restaurant of the hearing on Restaurant's requested liquor license constituted harmless error in the circumstances presented by this case; (2) The Department had sufficient grounds on which to deny Restaurant's liquor license; and (3) the court did not err in entering a judgment against Restaurant on its 42 U.S.C.S. 1983 claims. View "Antler's Inn & Rest., LLC v. Dep't of Pub. Safety" on Justia Law

After a jury trial, Defendant was convicted of intentional and knowing murder. The trial court sentenced Defendant to thirty-five years in prison. Defendant appealed, arguing (1) the court erred in denying him a new trial based on the State's failure to produce exculpatory evidence, (2) the court violated the equal protection right of a juror removed from the panel given his inability to deliberate past 5:08 p.m. for religious reasons, and (3) there was insufficient evidence to support his conviction. The Supreme Court affirmed the judgment, holding (1) Defendant received a fair trial in this matter; (2) there was no disparate treatment of the juror, and therefore, the juror's equal protection rights were not violated; and (3) there was no error in the trial court's entry of the judgment of conviction or its sentencing analysis. View "State v. Carr" on Justia Law

Employee filed this action against Employer and her four individual supervisors (Supervisors), claiming whistleblower discrimination pursuant to the Whistleblowers' Protection Act (WPA) and the Maine Human Rights Act (MHRA) and sex discrimination pursuant to the MHRA. The superior court granted Supervisors' motion to dismiss, finding they could not be held individually liable pursuant to the WPA and the MHRA. The court then entered summary judgment in favor of Employer on all claims. Employee appealed, contending (1) summary judgment for Employer was improper because she presented a prima facie case of whistleblower discrimination and there remained material facts in dispute, and (2) the dismissal of her claims against Supervisors was improper. The Supreme Court affirmed with respect to the sex discrimination claim and the dismissal of Supervisors but vacated the judgment with respect to the whistleblower discrimination claim against Employer, holding (1) material facts remained in dispute regarding Employee's whistleblower claim; but (2) the WPA and MHRA do not provide for individual supervisor liability. View "Fuhrmann v. Staples the Office Superstore E., Inc." on Justia Law

Following a nonjury trial, Defendant was convicted of domestic violence assault. Defendant's sentence included a period of two years of probation with a requirement that he participate in a certified batterers' intervention program. Defendant contended that his sentence violated the Equal Protection clauses of the U.S. and Maine Constitutions because, he asserted, a woman convicted of the same crime could not be sentenced to a term of probation of more than one year. The Supreme Court vacated the sentence and remanded for additional proceedings because there was no factual record from which the Court could evaluate Defendant's and the State's arguments. View "State v. Mosher" on Justia Law

The Board of Licensure in Medicine revoked Petitioner's medical license. The superior court dismissed Petitioner's complaint seeking judicial review, concluding (1) it lacked subject matter jurisdiction to review the Board's decision because the district court had exclusive jurisdiction to review nonconsensual license-revocation orders pursuant to Me. Rev. Stat. 10, 8003(5); and (2) Petitioner's 42 U.S.C.S. 1983 claim should be dismissed because the Board members had authority to revoke her license and were immune from suit. The Supreme Court affirmed, holding (1) the superior court properly dismissed Petitioner's petition for review of the Board order revoking her license because the district court had exclusive jurisdiction in such matters; and (2) because the Board acted within its authority in revoking Petitioner's license and, on appeal, Petitioner did not otherwise assert a denial of her constitutional rights, Petitioner's section 1983 claim was properly dismissed. View "Michalowski v. Bd. of Licensure in Med." on Justia Law

Defendant appealed from a judgment of conviction of one count of murder and one count of manslaughter entered in the trial court following a jury trial. Defendant argued that the trial court erred in denying his motion to suppress a confession, other statements, and physical evidence found as a result of the statements. The Supreme Court affirmed the judgment, holding that the trial court did not err in (1) finding Defendant was not in custody during the first interrogation; (2) failing to suppress Defendant's post-warning statements because the detectives' actions did not reflect a deliberate strategy to use "Miranda-in-the-middle," a two-step interrogation procedure; and (3) concluding that the State proved beyond a reasonable doubt that Defendant's post-warning statements were voluntary in light of the totality of the circumstances. View "State v. Nightingale" on Justia Law

Defendant was charged with the murder of her estranged husband. Following a jury trial, Defendant was found guilty of attempted murder, elevated aggravated assault, and false public alarm or report. Defendant appealed, asserting that the trial court made several evidentiary errors and that improper statements made by the prosecutor during the trial constituted prosecutorial misconduct that deprived her of a fair trial. The Supreme Court concluded that no evidentiary errors occurred and focused its discussion on Defendant's assertions of prosecutorial misconduct. The Court affirmed the judgment, holding that any prosecutorial misconduct, even considered cumulatively, did not affect the jury's verdict, and therefore, Defendant received a fair trial. View "State v. Dolloff" on Justia Law

Defendant appealed from a judgment of conviction entered in the trial court finding him guilty of four counts of criminal threatening with a dangerous weapon, eleven counts of criminal restraint with a dangerous weapon, twenty-two counts of kidnapping, one count of burglary, and one count of criminal restraint. The Supreme Court affirmed, holding (1) Defendant was not denied his right to speedy trial; (2) Defendant was not denied his right to self-representation; (3) the jury instructions accurately and fairly informed the jury in all necessary aspects of the law; (4) the court did not err by not dismissing the kidnapping charge; (5) there was sufficient evidence for the jury to find Defendant held the kidnapping victims for a "substantial period of time"; and (6) the court properly imposed consecutive sentences. View "State v. Hofland" on Justia Law

Defendant appealed from a judgment of conviction entered by the trial court following his conditional guilty plea to manslaughter. Defendant contended (1) the trial court erred in denying his motion to suppress statements he made to police officers during the investigation of his infant daughter's death, and (2) the juvenile court erred by admitting hearsay evidence during Defendant's juvenile bind-over hearing. The Supreme Court affirmed the judgment, holding (1) any statements made by Defendant during interrogations were not subject to the requirements of Miranda and were therefore not excludable on those grounds, the court properly considered Defendant's juvenile status, and the court did not err in concluding that Defendant's confession was voluntary; and (2) the court did not err by treating the hearsay testimony during the bind-over hearing as reliable, and therefore, its admission was not error. View "State v. Jones" on Justia Law