Justia Maine Supreme Court Opinion Summaries

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

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

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

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

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

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

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (1)(B)(2). Specifically, the Court held (1) the district court’s findings were supported by competent evidence in the record; (2) the district court adequately explained how Mother abandoned the child and how she failed to alleviate jeopardy, to engage in reunification services, and to protect the child in a time reasonably calculated to meet the child’s needs; and (3) the court did not abuse its discretion in determining that termination of Mother’s parental rights and adoption were in the child’s best interest. View "In re Tacoma M." on Justia Law

The Supreme Judicial Court affirmed the termination of the parental rights of Mother to two of her children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (1)(B)(2) due to the gross sexual assault committed by Mother against her oldest daughter. Mother was sentenced to a term of years for the gross sexual assault. The Court held that the district court adequately explained how Mother failed to alleviate jeopardy, failed to engage in rehabilitative services, and failed to protect the children or be available to take responsibility for the children within a time reasonably calculated to meet their needs. View "In re Mariah Y." on Justia Law

The Supreme Judicial Court affirmed the termination of the parental rights of Mother and Father due to persistent concerns about the child’s basic health and safety, the parents’ inability to understand and respond to the child’s needs, Mother’s intellectual limitations, Father’s violence, and the parents’ history of substance abuse. Specifically, the Court held (1) there was competent evidence in the record to support the district court’s finding, by clear and convincing evidence, of one or more grounds of parental unfitness as to each parent; and (2) the court did not abuse its discretion in determining that termination of each parent’s parental rights was in the child’s best interest. View "In re Daniel H." on Justia Law

The Supreme Judicial Court affirmed the termination of the parental rights of Mother and Father to their child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2), holding (1) there was competent evidence in the record to support the district court’s findings, by clear and convincing evidence, that Mother and Father were unwilling or unable to protect the child from jeopardy or take responsibility for the child reasonably calculated to meet the child’s needs; and (2) the court did not err or abuse its discretion by determining that the best interest of the child was served by terminating the parental rights of Mother and Father. View "In re Jesse B." on Justia Law