Justia Maine Supreme Court Opinion Summaries

A Greek and Australian citizen and a U.S. citizen, who married in Australia, had a child together and lived in Australia before relocating to Greece. In late 2022, the family traveled to Maine for a planned vacation. On the day before their scheduled return to Greece, the mother informed the father that she and the child would not return with him. The father returned to Greece alone, while the mother and child remained in Maine, where the child began receiving developmental services and became integrated into the local community. The child was later diagnosed with autism and enrolled in a therapeutic program. The mother filed for divorce in Maine, and the father subsequently sought the child’s return to Greece under the Hague Convention on the Civil Aspects of International Child Abduction.The Maine District Court found that the mother wrongfully retained the child in Maine as of January 4, 2023, but that the father did not file a petition for the child’s return in a Maine court until April 19, 2024—more than one year later. The court also found that the child was well settled in Maine, with significant family support, stable living arrangements, and access to specialized services. Exercising its discretion, the court denied the father’s petition to return the child to Greece. The father appealed.The Maine Supreme Judicial Court determined that the order was reviewable under the collateral order exception to the final judgment rule. The court held that the District Court did not err in finding the date of wrongful retention, nor in concluding that the father’s petition was untimely under the Hague Convention. The court also affirmed the finding that the child was well settled in Maine and held that the District Court did not abuse its discretion in denying the petition for return. The judgment was affirmed. View "Xamplas v. Xamplas" on Justia Law

A married couple with three minor children separated after more than a decade together, with the wife returning to Maine with the children and the husband remaining in the marital home in Atlanta. The wife, who had been the primary homemaker, filed for divorce, seeking division of property, spousal support, child support, and attorney fees. The husband, who had a significantly higher income, continued to pay the mortgage on the marital home, which had substantial equity.The Maine District Court in Calais held a contested hearing and entered a divorce judgment. The court awarded shared parental rights, primary physical residence of the children to the wife, and divided the marital property by awarding the home to the husband but granting the wife half the equity. The husband was ordered to pay spousal and child support, as well as the wife’s attorney fees. The husband filed post-judgment motions seeking clarification and amendment, particularly regarding the calculation of spousal support and attorney fees. The court reaffirmed its findings, including imputing minimum-wage income to the wife and finding the attorney fee award reasonable. The husband then appealed.The Maine Supreme Judicial Court reviewed the case and found a clerical error in the District Court’s property distribution table, which double-counted the equity in the marital home. This error potentially affected the determinations of spousal support and attorney fees. The Supreme Judicial Court vacated the judgment as to the property distribution calculations and remanded for correction and reconsideration of spousal support and attorney fees in light of the corrected figures. The judgment was affirmed in all other respects. The Court denied the wife’s request for appellate attorney fees as sanctions but allowed her to seek such fees in the trial court. View "Newman v. Riser" on Justia Law

Deborah A. Chatfield filed for divorce from Frederick H. Chatfield Jr. on July 14, 2021. Frederick initially had legal representation, but his attorney withdrew in December 2021, leaving him to represent himself. A final hearing was held on August 23, 2024, which Frederick did not attend. The court granted the divorce and classified certain real estate in Rockport as marital property, ordering its sale. Frederick did not appeal the divorce judgment or request further findings of fact.Frederick later retained counsel and filed a motion for relief from judgment under M.R. Civ. P. 60(b), arguing that the property was nonmarital, the court lacked jurisdiction, and Deborah's belief that the property was marital was a mistake. The District Court (Rockland) denied the motion, finding that Frederick had not protected his interests during the original proceedings and had not provided justification for his absence. The court also found no credible evidence to support Frederick's claims.The Estate of Frederick H. Chatfield Jr. appealed the denial to the Maine Supreme Judicial Court. The court reviewed the denial for abuse of discretion, considering whether the lower court's findings were supported by the record, whether the court understood the applicable law, and whether the court's decisions were reasonable. The Supreme Judicial Court affirmed the lower court's decision, finding no abuse of discretion or clear error. The court noted that Frederick failed to protect his interests by not attending the hearing, not filing for further findings, and not appealing the original judgment. The court also found that the lower court had jurisdiction over the property and that Frederick did not meet the burden of proof required for relief under Rule 60(b). View "Chatfield v. Estate of Chatfield" on Justia Law

Katrina M. Welch filed a complaint seeking de facto parentage of the biological child of her former partner, Naomi R. Chavaree. Welch claimed she had undertaken a permanent, committed parental role, established a bonded relationship with the child, and that it was in the child's best interest to continue their relationship. Welch's affidavit detailed her involvement during Chavaree's pregnancy, the child's birth, and their life together until their separation. She asserted that she played an active role in the child's life, including co-parenting after their separation.The District Court (Biddeford, Sutton, J.) dismissed Welch's complaint for lack of standing, determining that Welch had not made a prima facie showing of the statutory requirements for de facto parentage. The court concluded that Welch's affidavit did not demonstrate that her relationship with the child was fostered or supported by Chavaree or that both parties understood or accepted Welch as a parent. Welch's request for an expedited hearing was also denied as moot.The Maine Supreme Judicial Court reviewed the case and found that the District Court abused its discretion by not holding a hearing to resolve disputed facts material to the issue of standing. The Supreme Judicial Court noted that Welch's affidavit, if accepted as true, could support a finding of standing and that there were bona fide issues of material fact regarding Welch's role and Chavaree's acceptance of that role. The court emphasized that a hearing was necessary to assess the credibility of the parties' conflicting affidavits.The Maine Supreme Judicial Court vacated the District Court's dismissal and remanded the case for further proceedings, including a hearing to determine the disputed facts related to Welch's standing to seek de facto parentage. View "Welch v. Chavaree" on Justia Law

Pamela J. (Tower) Weinle appealed a divorce judgment from the District Court (Skowhegan), which divided marital property and awarded Alan R. Tower spousal support and attorney fees. Weinle contested the spousal support, property distribution, and attorney fees. Tower died after the judgment and during the appeal process.The District Court awarded Tower $2,000 per month in general spousal support, $500 per month in reimbursement spousal support, and $12,325 in attorney fees. The court found that Weinle had engaged in economic misconduct by purchasing and selling property without Tower's knowledge and failing to comply with discovery obligations, which increased litigation costs. The court also noted that Weinle had a substantial income and financial resources, while Tower had limited income and poor health.The Maine Supreme Judicial Court overruled its previous decision in Panter v. Panter, which required dismissal of an appeal if a party died during its pendency. The court held that the death of a party does not moot the appeal regarding property rights. The court affirmed the District Court's judgment, finding no error in the spousal support award, property distribution, or attorney fees. The court noted that the spousal support obligation ceased upon Tower's death, as the divorce judgment did not specify that the support survived the death of either party. View "Weinle v. Estate of Tower" on Justia Law

Kathleen M. Barron filed for divorce from John D. Barron in April 2022. The District Court in Bangor held a contested bench trial where both parties testified and submitted evidence, including proposed calculations for the division of assets. The court ordered John to make a $57,790.17 payment to Kathleen to equalize the division of property, or the marital home, which also houses John's business, would be sold.John appealed the decision, arguing that the court did not make sufficient findings to support the equalization payment. He had filed a post-judgment motion for further findings of fact, which the trial court denied. The Maine Supreme Judicial Court noted that the divorce judgment lacked specific findings regarding the valuation and classification of assets, making appellate review impossible. The court highlighted that the trial court must provide express factual findings based on the record to support its decisions.The Maine Supreme Judicial Court vacated the judgment in part and remanded the case for further findings. The court emphasized that the trial court must independently assess the valuation evidence before equitably dividing marital property. The judgment was vacated concerning the distribution of property, while the remainder of the judgment was affirmed. The case was remanded for further proceedings consistent with the opinion, allowing the trial court discretion to reopen the evidence if necessary. View "Barron v. Barron" on Justia Law

Sokunthim Nou appeals from a divorce judgment entered by the District Court in which the court allocated property between her and Rotanak Huot and awarded shared parental rights and responsibilities and shared residency of their children. Sokunthim challenges the court’s property determinations on multiple grounds, but does not contest the custody determination. The court found that all the parties’ assets were marital because they were acquired during the marriage and through significant effort by both parties. The court allocated just over half of the net value of the parties’ properties to Sokunthim and the remainder to Rotanak. The court also found Sokunthim’s income to be $435,598, based largely on Rotanak’s testimony about Punky’s LLC’s daily sales.The District Court held a trial with both parties represented by counsel and interpreters present. The court heard testimony from the parties, a real estate broker, Sokunthim’s accountant, and her father. The court entered a comprehensive divorce judgment, determining that all the parties’ assets were marital and allocating them accordingly. The court’s judgment awarded Panyah LLC to Rotanak and implicitly awarded Punky’s LLC to Sokunthim. Sokunthim filed motions for additional findings of fact and conclusions of law and for a new trial, which the court denied.The Maine Supreme Judicial Court reviewed the case and found that the trial court’s determination of Sokunthim’s income was unsupported by the evidence. The court’s finding as to her income may have influenced other financial aspects of the judgment. Therefore, the Supreme Judicial Court vacated the division of property and child support award and remanded for further proceedings. The judgment was affirmed in all other respects. View "Nou v. Huot" on Justia Law

Kiril Lozanov and Capital City Renewables, Inc. (CCR) appealed a Superior Court decision granting summary judgment in favor of Lily B. Piel. Lozanov and CCR alleged that Piel, a former employee, accessed and disclosed Lozanov’s personal emails without authorization, which included confidential information about a wind project unrelated to CCR. Lozanov claimed that Piel’s actions led to increased child support obligations and health issues due to stress from related litigation.The Superior Court dismissed CCR’s claim for intrusion upon seclusion, as the company did not have a right to privacy in Lozanov’s emails. Lozanov’s claim for intentional infliction of emotional distress was also dismissed, as the court found Piel’s conduct was not outrageous enough to warrant such a claim. The court allowed Lozanov’s intrusion upon seclusion claim to proceed but ultimately granted summary judgment for Piel on all counts, finding no evidence that Piel’s actions caused the alleged damages.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Superior Court’s decision. The court found no evidence that Piel breached any duty owed to CCR or that her actions caused the damages claimed by Lozanov and CCR. The court also concluded that CCR's and Lozanov’s damages were too remote and speculative to support their claims. Additionally, the court noted that public policy considerations barred recovery, as Lozanov’s attempt to hide assets in a child support proceeding was contrary to the best interests of the child and public policy. View "Capital City Renewables, Inc. v. Piel" on Justia Law

Patrick Bolduc and Savannah Getchius were married in 2011 and have three minor children. Bolduc filed for divorce in 2021. After two unsuccessful mediations, a final divorce hearing was held in June 2023. The District Court awarded Bolduc sole parental rights and responsibilities and divided the marital property. The court found that Bolduc's property, purchased before the marriage, appreciated in value during the marriage due to both market forces and marital improvements.The District Court determined that the entire appreciation of the property during the marriage was marital property. The court also ordered Getchius to pay $325 weekly in child support and $10,000 of Bolduc's attorney fees. Bolduc filed motions for further findings and to alter the judgment, which the court mostly denied, except for making limited additional findings.The Maine Supreme Judicial Court reviewed the case. It affirmed the lower court's decision on the classification of the real property, agreeing that Bolduc did not meet his burden to prove that the appreciation was solely due to market forces. The court also upheld the child support order, finding no error in the calculation or the decision not to order Getchius to pay $1,800 for uninsured medical expenses. However, the court found that the attorney fee award was based on an affidavit that included fees unrelated to the divorce proceedings. The court vacated the attorney fee award and remanded for recalculation of the fees properly subject to an award in the divorce action. View "Bolduc v. Getchius" on Justia Law

Kateryna A. Bagrii sought to establish herself as a de facto parent of two children whose biological parents are John P. Campbell and Jie Chen. Bagrii claimed she had acted as a parent to the children since 2014, after Campbell brought them from China to Ukraine without Chen's consent. Bagrii and Campbell later married and moved to the United States with the children. Bagrii argued that she had taken on full parental responsibilities and that her relationship with the children was in their best interests.The District Court (Newport, Ociepka, J.) dismissed Bagrii’s complaint for lack of standing, finding that although she proved most elements required for de facto parentage, she failed to demonstrate that Chen had fostered or supported her relationship with the children or accepted her parental role. The court noted that Chen had not consented to the children's removal from China and had not known their whereabouts for several years.The Maine Supreme Judicial Court reviewed the case and affirmed the District Court's judgment. The court held that under the Maine Parentage Act, a person seeking de facto parent status must prove that all legal parents who appear and object to the petition have fostered or supported the relationship. The court found that Chen had not implicitly or explicitly consented to Bagrii’s parental role. The court also rejected Bagrii’s request to exercise parens patriae authority, stating that due process principles require proof of consent from all legal parents. Thus, the judgment dismissing Bagrii’s complaint for lack of standing was affirmed. View "Bagrii v. Campbell" on Justia Law