Articles Posted in Constitutional Law

by
The Supreme Judicial Court affirmed the judgment of the superior court granting the Department of Environmental Protection’s request for a permanent injunction prohibiting Dubois Livestock, Inc. and the Randrick Trust (collectively, Appellants) from denying the Department access for solid waste inspections. The court held (1) the superior court did not err in concluding that Me. Rev. Stat. 38, 347-C and 1304(4-A) permit the Department to enter Appellants’ property without consent or an administrative search warrant; and (2) the warrantless searches authorized by these statutes do not violate Appellants’ constitutional right to be free from unreasonable searches and seizures. View "State v. Dubois Livestock, Inc." on Justia Law

by
The Supreme Judicial Court affirmed the order of the trial court denying Defendant’s motion to dismiss a complaint charging him with operating under the influence (OUI). In his motion to dismiss, Defendant argued that because he had already been convicted on a complaint containing the identical charging language, forcing him to defend against the charge violated his rights under the federal and state constitutions to be free from double jeopardy. The Supreme Judicial Court affirmed, holding that, for the purpose of double jeopardy analysis, the two complaints did not arise from the same act or transaction and, therefore, the Double Jeopardy Clause did not require the dismissal of the complaint at issue. View "State v. Martinelli" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of criminal threatening with a dangerous weapon, following a two-day jury trial. Contrary to the arguments raised by Defendant on appeal, the Supreme Court held (1) the trial court did not abuse its discretion or violate Defendant’s rights under the Confrontation Clause by allowing testimony about statements of an unavailable witness; and (2) there was sufficient evidence to support the guilty verdicts on the two counts of criminal threatening with a dangerous weapon. View "State v. Hall" on Justia Law

by
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

by
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

by
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

by
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

by
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

by
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

by
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