Justia Maine Supreme Court Opinion Summaries

A jury convicted Defendant of unlawful sexual contact and of violating a condition of release. Defendant challenged his convictions on appeal, asserting (1) the superior court erred in denying his request to instruct the jury on assault as a lesser-included offense of unlawful sexual contact, and (2) there was insufficient evidence to find that he had "contact" with the victim in violation of his conditions of release. The Supreme Court (1) vacated the judgment of conviction for unlawful sexual contact, holding that the court failed to properly instruct the jury on assault as a lesser-included offense of unlawful sexual contact; and (2) affirmed the judgment of conviction for violating a condition of release, holding that there was sufficient evidence in the record upon which the jury could find every element of the offense of violating a condition of release beyond a reasonable doubt. View "State v. Gantnier" on Justia Law

Norman Budge and twenty-eight additional parties (collectively, Employees) filed a complaint for review of government action for the Town of Millinocket's (Town) amendments to its personnel policy originally adopted as a town ordinance. In the most recent amendment, the Town reduced its obligation for paying for the health insurance plan for its employees and established a new policy for the health insurance offered to retirees that resulted in the Town reducing its payment of the retirees' premiums. Employees alleged that, regardless of the policy language, this reduction was inconsistent with promises made to them either when they were hired or during their tenure with the Town. The superior court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the personnel policy did not create an enforceable contract between the Town and its employees; (2) the Town was not bound to pay Employees' retirement group hospitalization and life insurance premiums by virtue of promissory estoppel; and (3) the Town's reduction in benefits did not result in an unconstitutional taking. View "Budge v. Town of Millinocket" on Justia Law

After a jury trial, Appellant was convicted of gross sexual assault and two counts of aggravated assault. On appeal Appellant challenged the trial court's failure to sanction the State for what he asserted was a discovery violation and the court's exclusion of his computer expert from testifying at trial. The Supreme Court affirmed, holding (1) the court acted well within its discretion in denying Appellant's motion for sanctions; and (2) the court did not exceed its discretion in excluding Appellant's computer expert, given that the delay in supply the expert report to the State was due to Appellant's own failure to pay his expert, the information supplied to the State days before the trial was not complete, and the substantial deference afforded the trial court in determining the admissibility of expert testimony. View "State v. Silva" on Justia Law

Following a jury trial, Appellant was convicted of manslaughter, aggravated criminal operating under the influence, aggravated leaving the scene of a motor vehicle accident, and operating under the influence. The Supreme Court affirmed, holding (1) the evidence produced at trial permitted a rational jury to find Appellant guilty beyond a reasonable doubt on each of the counts in the indictment; and (2) the court did not err in failing to presume prejudice after an attempted jury tampering, failing to issue a curative instruction after an improper comment by the State, and prohibiting Appellant from impeaching a witness with an audio recording of prior inconsistent statements. View "State v. Cheney" on Justia Law

Plaintiff filed a complaint against her former employer, Adroscoggin County, alleging gender discrimination, constructive discharge, and retaliation. The superior court granted partial summary judgment in favor of the County dismissing the counts of constructive discharge and gender discrimination. The retaliation claim proceeded to trial, and the jury returned a verdict for the County. Plaintiff subsequently appealed from the partial summary judgment dismissing the constructive discharge claim. The Supreme Court affirmed, holding (1) notwithstanding its application in the labor and discrimination contexts, constructive discharge does not exist as an independent cause of action under Maine statutory or common law; and (2) because Plaintiff did not challenge the summary judgment denying her claim for gender discrimination or the judgment entered on the jury's verdict denying her claim for retaliatory discrimination, nor did Plaintiff allege that the actions giving rise to her alleged constructive discharge from employment were themselves a form of unlawful discrimination under the Maine Human Rights Act, Plaintiff's claim for constructive discharge failed. View "Levesque v. Androscoggin County" on Justia Law

Appellant Timothy Daniels appealed a superior court's grant of summary judgment in favor of Defendants Narraguagus Bay Health Care Facility and North Country Associates, Inc. Appellant contended that the court erred in concluding that Narraguagus and North Country were entitled to judgment as a matter of law on his disability discrimination and retaliation claims made pursuant to Maine's Human Rights Act. Appellant suffered a work-related injury to his right shoulder in 2007 and thereafter was given work restrictions by his physician that prevented him from performing all of the work duties he had previously handled. In 2008, Appellant underwent surgery and then began a leave of absence. A few months later, Appellant notified his employer that he was applying for more leave at her insistence. In that letter, Appellant also reported that he had been cleared for light duty work, accused his supervisor of refusing to accommodate his disability, and asked for light duty work. No work was afforded to Appellant as a result of that letter. Appellant suffered another work-related injury to his right shoulder in 2009, and, although he did not lose any time from work as a result of that injury, he was restricted to modified duty for the next three months. During that period Appellant was disciplined for performance issues. Early in November 2009, when Daniels no longer had any work restrictions, a new Narraguagus administrator gave Appellant a performance improvement plan for failing to complete some tasks at all and failing to complete other tasks on time. In November, 2009, in response to the complaint that he filed in 2008, the Commission issued Appellant a right-to-sue letter pursuant to the Human Rights Act. When state regulators visited Narraguagus to conduct a licensing inspection, they uncovered issues that resulted in fines to the facility. Narraguagus blamed Appellant for the negative inspection and terminated his employment on January 29, 2010. After his termination, Appellant filed a two-count complaint against Narraguagus and North Country. On appeal, Appellant advanced two theories of liability against North Country: (1) that it can be liable because it is part of an integrated enterprise with Narraguagus, and (2) that it acted in Narraguagus’s interest in discriminating against him. Finding multiple issues of disputed facts regarding North Country's involvement in the actions that Appellant claimed constituted discrimination and retaliation, the Supreme Court vacated the grant of summary judgment in favor of Defendants, and remanded the case for further proceedings. View "Daniels v. Narraguagus Bay Health Care Facility" on Justia Law

Richard Herzog was convicted of domestic violence assault and sentenced to twenty days in jail, all suspended, and two years of probation with conditions, including the condition that Herzog could not possess or use unlawful drugs or alcohol. The Supreme Court (1) affirmed the judgment of conviction, holding that the district court properly applied the law of self-defense and did not err in its factual findings; and (2) affirmed the sentence as modified, holding that the term of probation exceeded the statutory maximum, and thus, the sentence was adjusted to decrease the period of probation from two years to one year. View "State v. Herzog" on Justia Law

Following a jury trial, Timothy Mooney was found guilty of trafficking in prison contraband. Mooney appealed, arguing that the superior court erred by (1) allowing a corrections officer to testify about details of the incident giving rise to Mooney's criminal charge, and (2) allowing an investigator to testify as to additional charges that would have been brought against Mooney had another inmate cooperated with the investigation. The Supreme Court vacated Mooney's conviction, holding (1) the trial court did not abuse its discretion by admitting the corrections officer's testimony; (2) the trial court erred by admitting the investigator's irrelevant testimony in evidence; and (3) the error was not harmless. View "State v. Mooney" on Justia Law

Defendant Cory LaForge was charged with criminal operating under the influence. LaForge filed a motion to suppress evidence obtained as a result of the stop of his vehicle, arguing that the stop was not justified by an objectively reasonable suspicion of criminal conduct. The district court agreed and granted LaForge's motion. The Supreme Court vacated the suppression order, holding that, as matter of law based on the facts found by the motion judge, the stop of LaForge's vehicle by a police officer was justified based on an objectively reasonable articulable suspicion. Remanded for entry of an order denying the motion to suppress. View "State v. LaForge" on Justia Law

Following a joint jury trial, Jeffrey Williams was convicted of intentional or knowing murder and conspiracy to commit murder. The Supreme Court affirmed Williams's convictions, holding (1) Williams was not denied a fair trial when the court denied his motion to sever the trial, or, in the alternative, to hold a joint trial but with a separate jury for each defendant; (2) the court did not abuse its discretion in prohibiting cross-examination of a cooperating witness regarding Williams's prior arrests; (3) certain comments by the prosecutor in relation to the cooperating witness did not constitute improper vouching; and (4) the evidence was sufficient to support Williams's convictions. View "State v. Williams" on Justia Law