Justia Maine Supreme Court Opinion Summaries

In the case before the Maine Supreme Judicial Court, George E. Gooley appealed and Danielle L. Fradette cross-appealed from the District Court’s judgments on their post-divorce and post-trial motions. The court held that the specific provisions concerning parent-child contact and the computation of Gooley’s income, the determination of Gooley’s imputed income, and the award of Fradette’s attorney fees could not be meaningfully reviewed without clear and specific findings. Therefore, those parts of the judgment were vacated and sent back to the lower court for further findings.The couple had divorced and had two minor children. There were several modifications to the divorce judgment, most notably in relation to the children's contact schedule with each parent. Later, Gooley filed a motion for contempt, alleging that Fradette was not following the contact schedule set by the court. Fradette filed a motion for post-judgment relief, requesting modifications to parental rights and responsibilities and asking for attorney fees. Fradette later amended her motion to add her decision to move from Maine to Massachusetts as a basis for modification. The court approved the amendment and held a four-day hearing on the parties’ post-judgment motions.The court found that Fradette met her burden of demonstrating that there had been a substantial change in circumstances due to her plan to relocate to Massachusetts, and granted her motion for post-judgment relief in part. The court awarded Fradette primary residency of the children and the right of final decision-making for the children’s education, and awarded the parties shared parental rights and responsibilities in all other respects. Gooley was awarded contact with the children on specific weekends and Wednesday evenings. The court also ordered Gooley to pay Fradette attorney fees of $30,000.On appeal, the Maine Supreme Judicial Court affirmed the judgments in part but vacated the portions of the judgment related to parent-child contact, computation of Gooley’s income, determination of Gooley’s imputed income, and the award of Fradette’s attorney fees. The court remanded the case for further findings on these matters. View "Gooley v. Fradette" on Justia Law

The case involves Billie S., who appealed from a judgment by the District Court (Bangor, Roberts, J.) which terminated her parental rights to her children pursuant to 22 M.R.S. § 4055(1)(B)(2) (2023). The mother argued that the judgment did not provide sufficient independent findings of fact to support the termination of her parental rights. The Maine Supreme Judicial Court agreed with the mother's contention.The trial court based its decision on evidence from various sources including the Department of Health and Human Services caseworker's testimony, guardian ad litem reports, and the petitions for termination. However, the judgment simply incorporated the entirety of these sources as its "specific findings" instead of providing an independent articulation of the specific facts that formed the basis of the court’s ultimate findings regarding the mother’s parental unfitness and the best interests of the children.The Maine Supreme Judicial Court held that these were not the “specific findings of fact” required by Rule 52(a) or prior decisions. The court could not infer factual findings in a termination case when the adequacy of the findings was the issue at hand. As a result, the court vacated the judgment due to its lack of adequate findings that would sufficiently inform the mother and the court of the reasoning behind the decision. The case was remanded to the District Court for further proceedings consistent with this opinion. View "In re Children of Billie S." on Justia Law

In this case, the Maine Supreme Judicial Court affirmed a lower court's decision to terminate a mother's parental rights to her two children. The mother appealed the termination of her rights, asserting that she was deprived of effective legal counsel during the proceedings. The lower court had determined that the children were in jeopardy due to the mother's chronic alcohol abuse, unsafe behavior, and poor decision-making, which included permitting a convicted sex offender to care for the children unsupervised. Despite repeated opportunities, the mother failed to demonstrate sufficient improvement to safely care for her children.The mother also proposed that her own mother or aunt should be appointed as permanency guardians for the children. However, the court found that neither individual was suitable for this role due to their loyalties to the mother and lack of objectivity regarding her addiction and reckless behavior. As such, the court determined that adoption was in the children's best interests.On appeal, the Maine Supreme Judicial Court found no evidence of ineffective assistance of counsel. The court noted that the attorney had adequately presented the mother's case and had advocated for the possibility of a familial permanency guardianship. The court concluded that the mother's claim of ineffective assistance did not meet the threshold for a prima facie case, as there was no evidence of serious incompetency, inefficiency, or inattention from her attorney, nor was there any indication that the outcome of the trial was unjust. Consequently, the decision to terminate the mother's parental rights was upheld. View "In re Children of Shannevia Y." on Justia Law

The Supreme Judicial Court affirmed the divorce judgment entered by the district court awarding Husband $35,500 of the marital equity in real estate owned by Wife and her father as joint tenants with one exception, holding that the findings and portion of the judgment regarding the valuation and division of marital property required vacatur.On appeal, Husband argued, among other things, that the trial court erred in valuing real estate as of the date the parties separated rather than the date that the parties divorced. The Supreme Judicial Court reversed in part, holding (1) the court did not err in its assessment of the marital equity in the real estate; and (2) the court erred as a matter of law in applying equitable principles to determine the marital property's value. The Court remanded the case for the trial court to determine the value of the marital equity in the real estate at the time of the divorce based on its independent assessment of the appraisal evidence in the record. View "Bolduc v. Bolduc" on Justia Law

The Supreme Judicial Court vacated in part the divorce judgment of the district court, holding that the district court erred in calculating past and future child support.On appeal, Father argued that the district court erroneously failed to account for changes in the parties' incomes and child care costs and to provide him with a downward deviation from child support guidelines and further erred in calculating his future child support obligation by excluding his child care costs. The Supreme Judicial Court vacated the court's child support order and remanded the case, holding that the trial court erred in its award of both past and future child support. View "McCarthy v. Guber" on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the district court allocating parental rights regarding the parties' child in this case, granting primary residence to Kyla Estes and defining rights of contact to Nicholas Capelety, holding that any error in the proceedings below was harmless.Capelety, who had a child with Estes, filed a complaint for determination of parentage, parental rights and responsibilities, and child support. Following a trial, the court issued a judgment determining parental rights and responsibilities. Capelety appealed, raising four assignments of error. The Supreme Judicial Court affirmed, holding that even if the court abused its discretion in enforcing the limits controlling the order and timing of presentation of evidence in this case, it was highly probable that the court's enforcement of the time limits did not affect the judgment. View "Capelety v. Estes" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Parents' parental rights to their children, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Judicial Court held that the district court (1) did not err when it found by clear and convincing evidence that both parents were unfit as parents and that the Department of Health and Human Services failed to meet its statutory obligations pursuant to 22 Me. Rev. Stat. 4041(1-A)(A); and (2) did not abuse its discretion when it found that termination of Parents' parental rights, rather than establishing a permanency guardianship, was in the best interests of the children. View "In re Children of Quincy A." on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the district court divorcing Katharine Allerding from Neill Ewing-Wegmann, holding that Allerding was not entitled to relief on her allegations of error.On appeal, Allerding challenged portion of the order awarding her and Ewing-Wegmann shared parental rights of their daughter and allocating Father's Day with the child to Ewing-Wegmann. Allerding also appealed the court's judgment ordering her to contribute to the fees of the appointed guardian ad litem (GAL). The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the trial court's determinations of rights of contact; and (2) the trial court did not abuse its discretion in allocating GAL fees. View "Ewing-Wegmann v. Allerding" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court ordering Torrey Sears's divorce from Bobby Sears but vacated the portion of the district court's order awarding Bobby spousal support, distributing the parties' property and debt, and awarding Bobby attorney fees, holding that the court's income and valuation findings did not provide a sufficient predicate to assess the specific awards.On appeal, Torrey argued that the district court erred in its financial rulings because it failed to conduct sufficient fact finding with respect to his income. The Supreme Judicial Court agreed and vacated the order in part, holding that while the district court's rulings appeared reasonable on this record, because the court failed to make sufficient findings regarding Torrey's income this court was unable to conduct appellate review of the majority of the court's financial rulings. View "Sears v. Sears" on Justia Law

The Supreme Judicial Court vacated in part the district court's amended divorce judgment in this action involving the modification of a divorce judgment, holding that the court erred in calculating child support by imputing an income to Mother that was higher than her actual income.The divorce judgment awarded Mother and Father shared parental rights and responsibilities as to their two children and allocated primary physical residence to Mother. Both parties later filed motions for contempt and Father moved to modify the judgment as to the children's residence, child support, and his rights of contact. The court granted Father's motion to modify and entered an amended divorce judgment. On appeal, Mother argued that the court erred in failing to find that her income was $37,287. The Supreme Judicial Court vacated the court's child support judgment and remanded the case, holding that the court's findings were insufficient to allow for effective appellate review because they did not indicate the court's basis for imputing income to Mother. View "Perreault v. Vallieres" on Justia Law