Justia Maine Supreme Court Opinion Summaries

Following a jury trial, appellant Michael Skarbinski was convicted on several counts, all of which arose from appellant's filing requests for tax refunds claiming no taxable income for three years when appellant had received substantial income. The supreme judicial court affirmed, holding (1) the court did not err when it instructed the jury on principles of tax law, and the court's instructions did not infringe upon the jury's role as fact-finder; (2) the court did not err in instructing the jury that if appellant believed the tax laws to be unconstitutional or illegal, or otherwise disagreed with them without an objectively reasonable good faith belief, his belief was not a defense to the charges; (3) the State's closing argument was not inflammatory and it did not improperly interject irrelevant issues into the case; and (4) the jury could have found each element of the offenses charged beyond a reasonable doubt, and the evidence was sufficient to support the convictions. View "State v. Skarbinski" on Justia Law

Defendant Philip Galarneau, III appealed his conviction as a âhabitual offenderâ for âoperating while under the influence.â In 2008, without a lawyer, Defendant pled not guilty to the charges in the district court. On the same day, an information containing the same charges was filed in the Superior Court where the State sought to revoke Defendantâs probation from a 2007 assault conviction. The district court charges were dismissed, and Defendant made his appearance at the probation revocation hearing at Superior Court. Defendant was appointed a lawyer-for-the-day. Defendantâs case was called, the court read the charges against him and asked both Defendant and his attorney whether he was advised of his rights. The court confirmed on record that Defendant waived his right to a trial, that he was pleading guilty to habitual offender and OUI charges, and that he admitted violating his probation. The Court sentenced Defendant to approximately two years for all the charges against him. On appeal to the Supreme Court, Defendant argued that his sentence and conviction were unconstitutionally imposed because the court did not inform Defendant of his right to counsel at the district court. The Supreme Court rejected that argument, finding that Defendant was represented by a lawyer-for-the-day during his initial appearance at Superior Court, and that the court confirmed Defendant was advised of his rights. The Court affirmed Defendantâs conviction and sentence.

âPenelope W.â appealed lower courtsâ decisions that involuntarily committed her to a state psychiatric center. In all aspects of her case, Penelope represented herself. The trial court concluded that she was mentally ill, and that she presented a likelihood of serious harm to herself and others. The appellate court denied Penelopeâs appeal because she failed to comply with the courtâs briefing requirements. On appeal to the Supreme Court, Penelope argued that she should not have been allowed to proceed at trial without counsel, particularly since involuntary commitment was at stake. The Supreme Court found although there is a limited right to self-representation in criminal cases, the same cannot be said for a civil commitment proceeding. The Court affirmed the trial courtâs decision that ordered Penelope to be committed.

Anthem Health Plans of Maine, Inc., appealed a judgment that affirmed a decision by the Superintendent of Insurance. The Superintendent determined that Anthemâs proposed average rate increase of 18.5% applicable to its individual health insurance products containing a built-in 3% profit margin was excessive and discriminatory. The Superintendent then indicated that an average 10.9% rate increase containing a 0% projected profit margin would be approved by his agency. Anthem contends that in setting a profit margin at 0%, the Superintendentâs decision eliminated Anthemâs opportunity to earn a reasonable profit. Anthem brought suit alleging the superintendentâs decision violates state law and the U.S. Constitution. The Supreme Court held (1) that because the year in which the challenged rates were effective has passed and new rates went into effect; (2) a favorable decision on the merits would not give Anthem any relief; and (3) because federal and state laws are in transition, there is no basis for the Court to address Anthemâs appeal from the Superintendent. The Court dismissed Anthemâs appeal as moot.