Justia Maine Supreme Court Opinion Summaries
Articles Posted in Family Law
Black v. Black
James Black appealed an order of the district court denying Dorothy Black’s motion for contempt but nonetheless ordering James to pay Dorothy a sum that the court determined he owed her pursuant to the parties’ divorce judgment. Specifically, James argued that the court lacked authority to grant Dorothy any form of relief upon denying her motion for contempt, which was not accompanied by a motion to enforce. The Supreme Judicial Court affirmed, holding that, under the unique circumstances of this case, the court acted within its authority by issuing an order requiring James to pay Dorothy the arrearage owed to her and that James was not unfairly prejudiced as a result. View "Black v. Black" on Justia Law
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Family Law
Quinty v. Johnson
Kimberly Quinty filed a motion to extend the spousal support provision of the divorce judgment granting a divorce to her and Steven Johnson. The district court granted Steven’s motion to dismiss Kimberly’s motion, concluding that reinstating the award of spousal support after the obligation to pay spousal support had expired was prohibited by law. The Supreme Judicial Court affirmed, holding that the district court correctly found that its authority to reinstate the spousal support award had ceased under to the parties’ settlement agreement, which was incorporated into the divorce judgment, and therefore, Quinty’s untimely motion failed to allege facts that would entitle her to relief. View "Quinty v. Johnson" on Justia Law
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Family Law
Knoblach v. Morris
The district court found John Knoblach in contempt for failing to pay spousal support to Stacylee Morris as required by the parties’ divorce decree and imposed a period of incarceration unless Knoblach paid the arrearage within a specified time. The Supreme Judicial Court affirmed, holding that the district court did not err or abuse its discretion by proceeding with the contempt hearing without objection on the scheduled date, and even if the district court erred by holding the contempt hearing one day too soon based on the amount of notice Knoblach was entitled to receive pursuant to Me. R. Civ. P. 66(d)(2)(C), Knoblach failed to demonstrate that the contempt order should be vacated. View "Knoblach v. Morris" on Justia Law
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Family Law
Bernsten v. Berntsen
Wife appealed from the judgment of divorce from Husband entered in the district court. The Supreme Judicial Court affirmed, holding that the district court did not err or abuse its discretion (1) by limiting Wife’s financial discovery from Husband’s current partner, a third party; (2) in its findings regarding the value of marital property; (3) by declining to find specifically that Husband’s discovery violations constituted economic misconduct; (4) in its findings supporting its award of spousal support and in failing to award Wife additional support; and (5) declining to award Wife attorney fees. View "Bernsten v. Berntsen" on Justia Law
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Family Law
Lentz v. Lentz
In this divorce case, the Supreme Judicial Court affirmed the judgment of the motion court, holding that the court did not abuse its discretion when it sanctioned Husband for disregarding his discovery obligations. Wife had filed a motion for sanctions based on Father’s continued noncompliance with discovery requests and orders. The motion court found that Husband had largely not complied with discovery orders and granted Wife’s motion. After the district court granted the divorce and divided the marital property, Husband appealed, arguing that the motion court’s sanctions against him resulted in an unjust division of property. Wife, in turn, filed a motion for sanctions alleging that Husband’s filings on appeal violated the Maine Rules of Appellate Procedure. The Supreme Judicial Court affirmed the judgment and declined to issue sanctions under the circumstances. View "Lentz v. Lentz" on Justia Law
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Family Law
Pyle v. Pyle
Husband appealed from a district court judgment awarding child support and primary residence of the parties’ children to Mother. The Supreme Judicial Court vacated the portion of the judgment related to the health insurance component of Husband’s child support obligation and affirmed the judgment in all other respects, holding (1) the district court did not err by awarding primary residence of the children to Mother; but (2) the district court committed clear error in its factual findings regarding the calculation of Father’s obligation to pay for the children’s health insurance. View "Pyle v. Pyle" on Justia Law
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Family Law
In re Paige L.
At issue here was the application of Me. Rev. Stat. 22, 4036(1-A) to preexisting parental rights orders. Section 4036(1-A) authorizes a court that has made a finding of jeopardy in a title 22 child protection proceeding to enter an order awarding parental rights and responsibilities if the court determines the order will protect the child from jeopardy and is in the child’s best interest. In this case, the trial court did not direct the opening of a family matters case as directed by section 4036(1-A)(A) but instead amended the parental rights and responsibilities order that had been issued in the parties’ previous divorce judgment that was in effect at the time of the jeopardy hearing. The trial dismissed the child protection action and awarded sole parental rights over the child to Mother by amending the preexisting parental rights and responsibilities order. The court further made a specific finding that Father created circumstances of jeopardy for his child. The Supreme Judicial Court affirmed the jeopardy order and the amended parental rights and responsibilities order, holding that the trial court did not abuse its discretion in reaching its ultimate conclusion. View "In re Paige L." on Justia Law
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Family Law
In re Kayleigh P.
The Maine Supreme Judicial Court upheld the termination of father’s parental rights, 22 M.R.S. 4055(1)(B)(2) as in the best interests of the children. The lower court found by clear and convincing evidence that Father was unable to protect the children from jeopardy or to take responsibility for them within a time reasonably calculated to meet their needs. The court noted that: the children had been neglected in the care of their mother; Father’s partner has “a serious child protection history; at the time of their October 2014 removal from mother's custody, Father had not seen the children since January 2014; the children had been in foster care for two years since removal from their mother and have done well in foster care; Father did not understand the medical needs of the children: and Father did not make progress on a reunification plan or get mental health treatment required by the plan for his depression, PTSD, and ADHD issues. The guardian ad litem had recommended termination, noting that the children have a high-level of needs and need permanency. View "In re Kayleigh P." on Justia Law
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Family Law
Williams v. Williams
Donald Williams appealed a divorce judgment dissolving his marriage to Linda Williams. During the pendency of the appeal, Linda withdrew $8,100 in interim spousal support payments from the escrow account, which had been set aside to Linda in the divorce judgment. The parties later voluntarily dismissed the appeal. Linda filed a motion for post-judgment relief seeking the recovery of the money she had withdrawn from the escrow account during the appeal. The court granted Linda’s request and awarded her $8,100. The court then granted her $6,000 in attorney fees. The Supreme Court affirmed in part and vacated in part, holding (1) a general release signed by Linda in anticipation of the dismissal of the appeal relieved Donald of any obligation to compensate Linda for the interim spousal support payments because they were directly associated with the appeal; and (2) the court did not abuse its discretion in awarding attorney fees to Linda. View "Williams v. Williams" on Justia Law
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Family Law
In re Mya E.
Mother appealed from a judgment of the district court terminating her parental rights to her child. Mother’s parental rights were terminated largely due to her chronic substance abuse and mental health issues. The Supreme Judicial Court affirmed, holding that the district court’s findings indicating that Mother was unwilling or unable to protect the child from jeopardy and take responsibility for the child in a time reasonably calculated to meet the child’s needs were supported by clear and convincing evidence. Further, the district court did not abuse its discretion in finding that it was in the child’s best interest to terminate Mother’s parental rights. View "In re Mya E." on Justia Law
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Family Law