Justia Maine Supreme Court Opinion Summaries

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

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

Paul Clark obtained a temporary protection from abuse order on behalf of his thirteen-year-old son against Defendant Michelle Fundalewicz, the child’s mother and Paul’s ex-girlfriend. At the time, the child resided with Paul and Paul’s then-fiancée (now wife), Miranda Clark. The child received a phone call on the home’s landline while Paul or both Paul and Miranda were not home. The child eventually revealed that Defendant had called him earlier that day. Paul reported the incident to the police. The child provided a written statement to the police stating that Defendant did call and speak with him. The State charged Defendant with violation of a protection order; Defendant pled not guilty to the charge and the matter proceeded to a jury-waived trial. At trial, the child testified that it was instead his cousin who called him. He testified that he said it was Defendant in his written statement to police because Paul had told him that if he did not name Defendant, the child would have to move back in with his mother where he would "get treated like crap" as he had been when he lived with her in the past. Miranda testified that a few days after the incident, she spoke with Defendant on the phone, and Defendant admitted to having called and spoken with the child. At the close of the trial, Defendant orally moved for a judgment of acquittal on the grounds that "the State failed to establish a corpus for the offense charged" because the State did not provide "evidence independent of any potentially incriminating statements that [Fundalewicz] . . . made." The court denied the motion, found Defendant guilty of violating the protection order, and sentenced her to pay a $400 fine. Although largely circumstantial, the Supreme Court concluded that the evidence presented at trial, along with the reasonable inferences that could have been drawn from it, adequately supported the corpus delicti requirement, as well as the court’s finding that Defendant did in fact call her son in violation of the protection order. View "Maine v. Fundalewicz" on Justia Law

Daniel Whitney appealed his conviction on one count of operating under the influence following his conditional guilty plea. Whitney argued on appeal that the trial court erred in issuing an order denying his motion to suppress evidence derived from a police officer's stop of his vehicle. Because the Supreme Court concluded that the stop was unconstitutional, it vacated the judgment and the order denying the motion to suppress. View "Maine v. Whitney" on Justia Law