Justia Maine Supreme Court Opinion Summaries

A woman and a man, both originally from the Middle East, met in the United States and traveled to Dubai, United Arab Emirates, in 2019 for a religious marriage ceremony conducted remotely by an imam in Maine. No religious official was present in person in Dubai. The ceremony followed Islamic traditions, and the imam issued a certificate of religious marriage. The couple later held a wedding reception in Turkey, where they and two witnesses signed the certificate. They returned to Maine but did not complete any ceremony or licensing required by Maine law, though the woman attempted unsuccessfully to certify the marriage at a local city hall before filing for divorce.The woman then filed for divorce in the Maine District Court in 2024. The man moved to dismiss, arguing there was no lawful marriage. After an evidentiary hearing, the District Court (Biddeford) granted the motion, finding the parties had not complied with Maine’s marriage statutes and were not legally married in Maine or elsewhere. The court also rejected the argument that any exception under Maine law applied, and dismissed the divorce complaint. The woman timely appealed.The Maine Supreme Judicial Court reviewed the case and held that the validity of a marriage is determined by the law of the jurisdiction where the marriage ceremony occurred, not Maine law, unless the marriage is contrary to Maine’s basic public policies. Since the ceremony was in Dubai, the question was whether the marriage was valid under the laws of the United Arab Emirates. The Court found that the woman had not addressed this question at trial or on appeal and therefore waived the argument. The Maine Supreme Judicial Court affirmed the District Court’s judgment dismissing her complaint for divorce. View "Aldarraji v. Alolwan" on Justia Law

Amelia Johnson sought a protection-from-abuse order for herself and her minor child against Michael Osseyran, the child’s father. She filed her complaint in December 2024, alleging that Osseyran’s actions toward her and their child constituted abuse. The court issued a temporary protection order and temporarily awarded Johnson parental rights. At a final hearing, Johnson testified about incidents where Osseyran physically disciplined the child, describing grabbing and yelling. An investigations caseworker from the Department of Health and Human Services and a friend of Osseyran’s also testified. The court reviewed evidence including text messages between the parties.The District Court (Portland) found that while the parties’ child was difficult to parent and Osseyran’s actions may have been offensive, Osseyran had not engaged in stalking, threatening, or harassing behavior toward Johnson or the child. The court concluded that his actions were attempts to parent, not abuse, relying on statutory language that allows a parent to use a reasonable degree of force when disciplining a child. The court declined to issue a final protection-from-abuse order and dismissed the temporary order. Johnson appealed, arguing that the evidence required a finding in her favor, the District Court misapplied the statute, and that it had admitted inadmissible hearsay evidence.The Maine Supreme Judicial Court reviewed the case. It held that the evidence did not compel a finding that Johnson was entitled to a protection-from-abuse order, that the District Court correctly interpreted the statutory definitions of abuse, and that although hearsay evidence was admitted in error, it did not result in prejudice warranting reversal. The Court modified the judgment to correct a clerical error regarding the parties’ attendance at the hearing but otherwise affirmed the District Court’s judgment. View "Johnson v. Osseyran" on Justia Law

A married couple entered into a premarital agreement prior to their 2015 wedding. The agreement stated that each party’s property, including business interests owned prior to or acquired during the marriage, would remain separate and nonmarital. It also included a provision anticipating that the husband would purchase a condominium, which would become the marital home and, in the event of divorce, its value would be split equally. During the marriage, the couple resided in the condominium, but it remained owned by the husband’s mother, and the husband never purchased it. The couple separated in 2020, and the husband filed for divorce in 2021. Throughout the marriage, the husband acquired and managed various business interests, while both parties maintained separate finances.The Maine District Court in Portland held several hearings to resolve issues related to spousal support, discovery sanctions, and the interpretation and validity of the premarital agreement. The parties stipulated that the agreement was valid but disputed its scope, particularly regarding business interests and the condominium provision. The District Court found that the wife had waived any claim to the husband’s business interests and any increase in their value, and that the agreement did not require the husband to purchase the condominium. The court also determined it lacked jurisdiction to consider the wife’s breach-of-contract claim regarding the condominium and awarded her a portion of her requested attorney fees.Upon appeal, the Maine Supreme Judicial Court vacated the District Court’s judgment in part. It held that the wife had clearly waived any claim to the husband’s business interests and their increases in value. However, the Supreme Judicial Court determined that the lower court erred in concluding it lacked jurisdiction over the breach-of-contract claim concerning the condominium and in interpreting the agreement as not requiring its purchase. The case was remanded for further proceedings consistent with these holdings. View "Hutchinson v. Gomez" on Justia Law

John M. Carter and Ann C. Martin were married in 2015. Carter initiated divorce proceedings in March 2023. On June 6, 2025, a hearing was held in the Maine District Court, at which both parties testified remotely. The court orally announced that the divorce would be final as of that day if both parties filed waivers of appeal. Carter filed his waiver that same day, but Martin did not. The court determined that additional real estate orders were needed before finalizing the judgment. Before the court signed the final written judgment and the real estate orders on July 3, 2025, Carter died on June 27, 2025.Following Carter’s death, Martin filed a motion for relief from or to alter the judgment, arguing that the court lacked jurisdiction to enter a final divorce judgment after Carter’s death. The District Court denied her motion, citing Boland v. Belair, and reasoned that the settlement the parties had reached should be binding. Martin then appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the case de novo and held that because Carter died before the court signed the final judgment, the marriage was automatically terminated by death. Therefore, the District Court no longer had subject matter jurisdiction to enter a divorce judgment, as there was no longer a marriage to dissolve. The Supreme Judicial Court ruled that the judgment signed after Carter’s death was void and that the use of nunc pro tunc was not valid to retroactively finalize the divorce. The court vacated the District Court’s judgment and remanded the case with instructions to dismiss the divorce action. View "Estate of Carter v. Martin" on Justia Law

A married couple acquired real estate in Bucksport, Maine, during their marriage and operated a short-term rental business on the property through a jointly owned limited liability company (LLC). They also owned a 2009 SeaRey airplane, acquired during their marriage. After the wife obtained a protection from abuse order against the husband in June 2022, she operated and maintained the business and prepared the real estate for sale without his involvement. The parties reached a partial settlement on some divorce issues, but disputed the division of the Bucksport property, the status and value of the airplane, and the dissolution of the LLC.The District Court in Bangor entered a divorce judgment incorporating the parties’ partial agreement. The court awarded the wife 60% of the value of the Bucksport real estate, attributing the increase in value to her post-separation efforts. It determined the airplane was marital property used primarily for personal purposes, valued it at $37,500, and awarded it to the husband, requiring him to compensate the wife for her share or to sell and divide the proceeds. The court also ordered the dissolution of the LLC and distribution of any profits. The husband appealed, challenging the division of real estate, the airplane’s use and valuation, and the dissolution of the LLC.The Maine Supreme Judicial Court affirmed the District Court’s finding that the airplane was marital property and not a business asset, but vacated the valuation of the airplane, finding insufficient evidence to support the assigned value. The Court also held that the District Court lacked jurisdiction to order dissolution of the LLC as part of the divorce. The judgment was vacated as to the distribution of the Bucksport real estate, the airplane’s valuation, and the LLC dissolution, and the case was remanded for further proceedings consistent with these rulings. The divorce judgment was otherwise affirmed. View "Adams v. Delong" on Justia Law

A mother, Cassie S., was subject to a child protection proceeding after concerns were raised about her medical decision-making for her child, who had a complex medical history. Despite multiple recommendations from medical providers to remove the child’s tracheostomy and gastrostomy tube, the mother insisted on maintaining these interventions and sought further procedures. After a New York hospital visit revealed no medical basis for these interventions and the mother refused to allow further evaluation, the hospital reported suspected medical abuse to Maine’s Department of Health and Human Services, which then petitioned for a child protection order.The District Court in Portland initially struggled to serve the mother and obtain necessary medical records, in part because of the mother’s resistance. The court denied her request for appointed counsel after finding she was not indigent, but she eventually retained private counsel for the hearing. The court granted a continuance of the jeopardy hearing beyond the statutory 120-day deadline due to delays attributed to the mother and the complexity of the case. Following a hearing, the court found the child was in jeopardy, placed the child in the Department’s custody, and required steps toward demedicalization and psychological evaluation for the mother. The court also issued a broad order restricting the mother from discussing the case publicly. The mother’s motion for relief from judgment based on alleged ineffective assistance of counsel was denied without a hearing.The Maine Supreme Judicial Court affirmed the finding of jeopardy and the denial of the mother’s Rule 60(b) motion, holding that she was not entitled to appointed counsel, the continuance was justified for good cause, there was no error requiring recusal, and any negative inference regarding missing witnesses was harmless. The Court vacated the speech restriction order as overly broad and remanded for it to be narrowed and time-limited. View "In re Child of Cassie S." on Justia Law

A mother’s parental rights were terminated after her child was born drug-affected, prompting the Department of Health and Human Services to seek a child protection order. The mother, struggling with opioid use disorder, spent significant periods in jail and various treatment facilities. Despite participating in an Adult Treatment and Recovery Court program, she experienced multiple relapses and did not complete her treatment programs. At the time of the termination hearing, she remained in treatment with no clear plan for when she could care for her child.The District Court (Springvale) conducted a hearing on the Department’s petition to terminate parental rights. The court received evidence that the mother had a long-standing substance use disorder and inconsistent participation in treatment. The guardian ad litem (GAL) assigned to the case did not meet several statutory obligations, including meeting the mother in person, observing visits, attending family meetings, and filing timely reports. Nevertheless, the court found the mother unfit based on statutory criteria and concluded that termination was in the child’s best interest. The mother appealed, arguing that the court misunderstood addiction and that deficiencies in the GAL’s performance undermined the best interest determination.The Maine Supreme Judicial Court reviewed the case for clear error and abuse of discretion. The court held that the evidence supported a finding of parental unfitness under at least one statutory ground, and deficiencies in the GAL’s performance did not prevent the trial court from independently determining the child’s best interest. The court also found no abuse of discretion in the trial court’s decision not to explicitly consider a permanency guardianship. Accordingly, the Maine Supreme Judicial Court affirmed the judgment terminating the mother’s parental rights. View "In re Child of Danielle H." on Justia Law

A couple who had served as resource parents for a child involved in a protective custody proceeding filed a petition to adopt the child. Their petition was denied by the District Court, which instead granted adoption to another couple. The District Court based its decision on its determination that adoption by the other couple was in the child’s best interest. The resource parents appealed to the Maine Supreme Judicial Court, which affirmed the District Court’s decision, finding no clear error or abuse of discretion.Almost a year later, the resource parents filed several motions in the District Court, including a motion under Maine Rule of Civil Procedure 60(b) seeking relief from the adoption judgment. They argued that the adoptive parents had fraudulently misrepresented the nature of their relationship during the adoption proceedings and that new evidence supported their claim. The District Court denied these motions with prejudice, later providing a more detailed explanation. The court found the proffered evidence to be either discoverable at the time of trial, related to events occurring after judgment, or insufficient to prove fraud by clear and convincing evidence. The court also declined to hold an evidentiary hearing and ordered the resource parents to pay the adoptive parents’ attorney fees and costs.On appeal, the Maine Supreme Judicial Court reviewed the denial of the Rule 60(b) motion for abuse of discretion and the attorney fee award de novo. It concluded that the District Court did not abuse its discretion in denying relief from judgment or in declining to hold an evidentiary hearing, as the evidence was either not newly discovered or did not meet the heightened standard for fraud. However, the Supreme Judicial Court vacated the portion of the order awarding attorney fees, finding no basis for a sanction, and otherwise affirmed the judgment. View "Adoption by Kathleen C." on Justia Law

Kathleen L. Jellison filed for divorce from Ralph E. Jellison, and the District Court incorporated the parties’ agreement regarding the division of marital assets. Kathleen was awarded the marital home, valued at $250,000 and subject to a $45,823.58 home equity loan, while Ralph received the Verso 401(k) account with a similar value. Both parties and the court agreed this was an equitable division, though Kathleen later contended she had not entered the agreement knowingly and voluntarily, and sought to hold Ralph responsible for half of the home equity debt.After the original judgment, Kathleen filed post-judgment motions, and the District Court amended its judgment to order Ralph to pay $30,000 from his 401(k) to Kathleen, which she was to apply to the home equity loan. Kathleen appealed, arguing the asset division remained inequitable. The Maine Supreme Judicial Court affirmed the amended judgment in Jellison v. Jellison, Mem-24-115. Ralph did not cross-appeal.Subsequently, Ralph filed motions for relief from judgment under Rule 60(a) and then Rule 60(b), arguing that the provision requiring him to pay $30,000 was a mistake. The District Court granted relief under Rule 60(b), striking the payment provision and amending the judgment. Kathleen appealed this order.The Maine Supreme Judicial Court held that the District Court erred in granting Ralph’s Rule 60(b) motion because it conflicted with the appellate mandate affirming the amended judgment. The Supreme Judicial Court clarified that a lower court may not modify matters expressly or impliedly disposed of on appeal, and Rule 60(b) is not a substitute for appellate review or a means to challenge issues not raised on direct appeal. The order granting Ralph’s motion for relief from judgment was vacated, and the case was remanded with instructions to deny the motion. View "Jellison v. Jellison" on Justia Law

The parties in this case are the parents of a ten-year-old daughter and share equal residential care for her. Their original 2016 order set a child support obligation for the father, but a 2020 amended agreement reduced this obligation to zero, reflecting their arrangement of equal parenting time. In December 2023, both parties filed motions seeking modification of the parental rights and responsibilities order. During the pendency of these motions, the father had a son with another person, but the son was not covered by the child support order at issue.Following a hearing, the Maine District Court (Biddeford) ordered the father to resume paying child support to the mother and denied his request for a downward adjustment based on his obligation to support his new son. The District Court reasoned that under Maine’s statutory scheme, only a nonresidential parent—rather than a coresidential parent like the father—could receive such an adjustment. The court subsequently denied the father’s motion to alter or amend the judgment.On appeal, the Maine Supreme Judicial Court reviewed the statutory interpretation of 19-A M.R.S. § 2006(5)(A) de novo. The Court held that when both parents provide substantially equal care, neither is the “primary care provider” referenced in the statute. Therefore, the statutory provision allowing a child support adjustment for a parent who is not the primary care provider applies. Because the father was legally obligated to support his son in his household and neither party was the primary care provider for their daughter, the Court determined he was entitled to the statutory adjustment. The Maine Supreme Judicial Court vacated the District Court’s child support order and remanded the matter for recalculation consistent with its interpretation. View "Waterman v. Wheeler" on Justia Law