Articles Posted in Constitutional Law

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The Supreme Judicial Court affirmed the judgment of the superior court dismissing Plaintiffs’ constitutional and statutory claims against the Commissioner of the Department of Health and Human Services and two Department employees. Plaintiffs alleged the same facts in an earlier action filed in federal court arising out of the same allegedly wrongful acts. The federal court dismissed all claims against the Commission for failure to state a claim upon which relief could be granted and dismissed the claims against one of the employees for Plaintiffs’ failure timely to serve her. Approximately one year later, Plaintiffs filed this action. The superior court dismissed all of Plaintiffs’ claims, concluding that the claims against all three defendants were barred by the claim preclusion component of the doctrine of res judicata. The Supreme Judicial Court affirmed, holding that the superior court did not err by dismissing Plaintiffs’ claims against the two employees on claim preclusion grounds because the employees had a sufficiently close relationship to the Commissioner to satisfy the requirement of claim preclusion of “sufficient identically between the parties in the two actions.” View "Estate of Paul F. Treworgy v. Commissioner, Department of Health & Human Services" on Justia Law

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In this class action, the Supreme Judicial Court affirmed the judgment of the superior court declining to grant declaratory and injunctive relief from alleged violations of constitutional rights arising from the York County Probate Court schedule ordered by former York Court Probate Judge Robert Nadeau. While Plaintiff’s appeal was pending, Judge Nadeau filed a motion to dismiss, arguing that the case became moot when he lost the election for the probate judgeship. The Supreme Judicial Court held (1) this appeal was is moot; and (2) the superior court did not err in determining that Judge Nadeau’s altered court schedule did not result in delays in these routine cases that rose to the level of constitutional deprivations, and Judge Nadeau did not violate the class members’ substantive due process rights as litigants in the York County Probate Court. View "Legrand v. York County Judge of Probate" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the postconviction court denying Defendant’s petition for postconviction review seeking relief from a judgment convicting Defendant of theft by misapplication of property and securities fraud. In his petition for postconviction review Defendant alleged ineffective assistance of trial counsel during plea negotiations and at trial, resulting in prejudice. In its judgment, the court found that Defendant’s arguments did not warrant relief. The Supreme Judicial Court affirmed, holding that the postconviction court was not compelled to find that Defendant established deficient representation or prejudice during either plea negotiations or trial. View "Philbrook v. State" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her child. Contrary to Mother’s contentions, the court held (1) Mother was not deprived of due process because the district court afforded her sufficient notice of the termination hearing before terminating her parental rights and did not place undue weight not he earlier termination of Mother’s rights to another child; and (2) the court’s findings were sufficient as a matter of law, and the court’s judgment was the “result of the application of independent judicial thought to the process of making fact-findings and conclusions.” View "In re Zoey H." on Justia Law

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The Supreme Judicial Court affirmed Defendant’s sentences totaling sixty years following Defendant’s guilty plea to four counts of gross sexual assault. This was Defendant’s second appeal arising out of the events that led to these charges. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court was not required to find specific aggravating circumstances before imposing what Defendant claimed was a de facto life sentence; and (2) the trial court did not impose an illegal sentence because Defendant's aggregate sentence was neither disproportionate to the offenses charged, nor did the sentence offend prevailing notions of decency. View "State v. Hoover" on Justia Law

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In 1970, Beauchene was acquitted of a murder charge by reason of mental disease or defect and was committed to the custody of the Department of Health and Human Services, where he remains committed pursuant to 15 M.R.S. 103. In 2016, Beauchene filed a petition seeking a discharge or a modified treatment plan. The court held a hearing at which three mental health professionals testified. The court denied the petition, finding that Beauchene had been diagnosed with “explosive personality,” had escaped from custody in 1973 and was returned to custody in 1978, had escaped again and fled to New York, where he was convicted of rape, sodomy, and assault in 1980, and has mental health symptoms consistent with anti-social personality disorder. The court concluded that Beauchene’s mental condition has “changed very little, if any[,] since” 1970, and if discharged, released, or placed in a modified treatment plan, Beauchene would pose a risk of harm or danger to himself or to others. The Maine Supreme Judicial Court affirmed, finding that Beauchene’s mental health symptoms constituted a “mental disease or defect” and that the statute provides sufficient notice and is not unconstitutionally vague and rejecting a due process claim. View "Beauchene v. State of Maine" on Justia Law

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Mother appealed from a judgment of divorce entered in the district court, arguing that the provision requiring each parent to transport, or allow the other parent to transport, the parties’ children to extracurricular activities violated her constitutionally-protected liberty interest in the care, custody, and control of her children. The provision was entered after a dispute between the parents over the children’s level of involvement in a developmental soccer league. The Supreme Judicial Court affirmed, holding (1) a court order that allows one parent to make the decision on a disputed child-related issue does not violate the constitutional rights of either parent; and (2) the court did not abuse its discretion in finding that continued participation in soccer was in each child’s best interest, or in ordering the default transportation provision. View "Mills v. Fleming" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court denying Mark Gessner’s petition for release from the Riverview Psychiatric Center. On appeal, Gessner argued that the statute governing his opportunity for release from institutional inpatient residency, Me. Rev. Stat. 15, 104-A, was unconstitutionally vague as applied to him. Because Gessner did not raise the vagueness issue to the trial court, the Supreme Judicial Court reviewed for obvious error. The court held (1) considering Gessner’s history of mental illness and violence and his refusal to acknowledge his mental illness or to participate in treatment, the statute’s terms were not unconstitutionally vague for purposes of addressing the individual circumstances at issue in this case; and (2) therefore, Gessner failed to meet his burden of demonstrating that the court committed obvious error. View "Gessner v. State" on Justia Law

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Plaintiff, conservator and guardian for his son Vincent Jones, and Plaintiff’s counsel (Attorney) appealed from two orders issued by the probate court that (1) dissolved and replaced a supplemental needs trust that had been created for Vincent’s estate, and (2) directed the Attorney, who created the original trust, to disgorge legal fees paid to her by Vincent and conditionally to pay additional amounts. The Supreme Judicial Court affirmed in part and vacated in part, holding (1) the probate court’s order creating a new supplemental needs trust for Vincent was not void for lack of statutory authority; and (2) the payment order against the Attorney deprived the Attorney of due process. View "In re Guardianship & Conservatorship of Jones" on Justia Law

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After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer. On appeal, Defendant challenged the constitutionality of Me. Rev. Stat. 17-A, 361-A(2), which creates a permissible inference that a defendant engaged in the conduct that constitutes the crime of theft under certain circumstances. The Supreme Judicial Court affirmed, holding (1) section 361-A(2) is sufficiently clear to give an ordinary person adequate notice of the type of conduct that gives rise to the permissible inference of the specified elements of theft; and (2) Defendant’s contention that section 361-A(2) is subject to, and fails to survive, strict scrutiny was not persuasive. View "State v. Flores-Montecinos" on Justia Law