Justia Maine Supreme Court Opinion Summaries

Dale and Diane Charette's divorce incorporated a settlement agreement in which the parties agreed that Dale would pay Diane $200 per week as general spousal support. The district court later reduced Dale's spousal support obligation to $165, finding that a reduction was warranted due to Dale's significantly changed medical circumstances. After Dale failed to make several of the reduced payments, the court first granted Diane's motion to enforce and then found Dale to be in contempt for failing to pay support as ordered. Dale, meanwhile, filed a second motion to modify, which the trial court denied. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in declining to further lower Dale's spousal support obligation on the ground that Diane was cohabitating with someone; (2) the court's factual finding that Dale was able to continue paying $165 per week in support was not clearly erroneous; and (3) the court did not err in ordering Dale to pay an additional $400 per month until the arrearage he had accumulated was cleared, as there was ample competent evidence to support the court's finding that Dale had the ability to make the additional payments. View "Charette v. Charette" on Justia Law

Plaintiff and Defended were divorced pursuant to a judgment that required Defendant to transfer paperwork to Plaintiff, assure that Plaintiff's tractor and snow blower were in working condition, and make property settlement payments to Plaintiff. Subsequently, Plaintiff obtained a final protection from harassment (PFH) order that prohibited Defendant from having any direct or indirect contact with Plaintiff. Some months later, Plaintiff filed a motion for contempt, alleging that Defendant had failed to comply with the divorce judgment. The court concluded that Defendant was not in contempt regarding the property settlement payment, the paperwork, the tractor, or the snow blower because Plaintiff had failed to prove that Defendant could comply with the judgment as to these items without violating the PFH order's no-contact provision. The Supreme Court vacated the judgment insofar as it found that the PFH order prevented compliance with the divorce judgment. Remanded. View "Waltz v. Waltz" on Justia Law

After a jury trial, Defendant was convicted for the intentional or knowing murder of his roommate. Defendant appealed, arguing that the trial court erred in concluding that he waived his Fifth Amendment privilege against self-incrimination and ordering him to answer a question posed by the State on cross-examination. The Supreme Court affirmed the conviction, holding that the trial court did not abuse its discretion (1) in determining that Defendant waived his Fifth Amendment privilege and in reasoning that the disputed question posed by the State was within the scope of his testimony on direct examination; and (2) in instructing the jurors that they could consider Defendant's unprivileged refusal to answer the State's question on cross-examination. View "State v. Butsitsi" on Justia Law

Plaintiff filed a complaint for protection from harassment against his former landlord (Defendant). Defendant moved for the entry of judgment as a matter of law after Plaintiff had presented his case. The court granted the motion, concluding that, even accepting all of Plaintiff's testimony as true, Plaintiff failed to demonstrate abuse or harassment within the meaning of the relevant statute. Plaintiff appealed, arguing that the court should not have reached its decision without affording Plaintiff the opportunity to play certain audio recordings and that the court should not have entered judgment as a matter of law. The Supreme Court affirmed, holding (1) the court did not err in proceeding based on the evidence that was presented at trial after it was clear the recordings were unavailable at the time of trial; and (2) because the evidence presented at trial failed to establish harassment, the lower court did not err in entering judgment as a matter of law. View "Chapman v. Robinson" on Justia Law

In the late 1990s, Bryan Carrier pled guilty to three counts of vehicular manslaughter and three counts of aggravated operating under the influence. The judgment and commitment notified Defendant that his license was suspended for life on the manslaughter counts. In 2011, Carrier petitioned for reinstatement of his license. After a hearing, a hearing officer of the Secretary of State's Bureau of Motor Vehicles denied Carrier's petition based on the opposition of the victims' families. The superior court denied Carrier's petition for judicial review. The Supreme Court affirmed, holding that the reinstatement statute allows for consideration of the opinions of the victims and their families. View "Carrier v. Sec'y of State" on Justia Law

When Restaurant was denied a requested liquor license by the Town of Bingham, Restaurant appealed to the Department of Public Safety. After a hearing, a Department hearing officer also denied the license. On appeal, Restaurant asserted various independent claims alleging constitutional and statutory violations by the Department and Town. The appellate court found in favor of Defendants on Restaurant's independent claims but, on the merits, remanded the matter to the Department after concluding that an appeal of a municipality's denial of a liquor license could only be decided by the Commissioner of Public Safety and not a hearing officer. On remand, the Commissioner of the Department denied the license application. The Supreme Court affirmed, holding (1) the deficiencies in the Department's notice to Restaurant of the hearing on Restaurant's requested liquor license constituted harmless error in the circumstances presented by this case; (2) The Department had sufficient grounds on which to deny Restaurant's liquor license; and (3) the court did not err in entering a judgment against Restaurant on its 42 U.S.C.S. 1983 claims. View "Antler's Inn & Rest., LLC v. Dep't of Pub. Safety" on Justia Law

Police brought Marcia E. to a Hospital's emergency room after Marcia lit herself on fire. Medical staff evaluated Marcia and determined that she meet the criteria for emergency involuntary admission pursuant to Me. Rev. Stat. 34-B, 3863. It was not until the third day, when the Hospital could accommodate Marcia in its psychiatric unit, that Hospital officials applied for the judicial endorsement necessary to formally admit Marcia to the Hospital on an emergency basis. The court gave its endorsement. Two days later, the Hospital filed an application for Marcia's involuntary commitment. Marcia sought dismissal of the petition on the basis that the Hospital violated the statutory procedure for emergency hospitalization by holding her for three days before seeking the judicial endorsement. The court denied Marcia's motion to dismiss and ordered Marcia's hospitalization. The superior court affirmed. The Supreme Court affirmed, holding that the Hospital's failure to comply with the procedural requirements for Marcia's emergency admission did not constitute grounds for dismissal of the separate involuntary commitment petition, as the Hospital met all the requirements necessary to involuntarily commit Marcia. View "In re Marcia E." on Justia Law

When Mother's child was eleven weeks old, Mother left the infant in the care of her boyfriend. The boyfriend shook the baby and threw it into the couch, resulting in severe injuries to the child. The district court placed the child in the custody of the Department of Health and Human Services, finding that the child was in immediate risk of serious harm due to Mother's inability to protect him from physical abuse. The court subsequently conducted a full testimonial hearing, after which it issued an order finding jeopardy as to Mother and maintaining custody with the Department. The court also ordered the Department to cease reunification efforts with Mother. The Supreme Court affirmed, holding that the court did not err in issuing the cease reunification order. View "In re B.C." on Justia Law

Relying on a licensed forester's markings of property boundaries, a company removed trees from 17.9 acres of Plaintiff's property. Plaintiff sued the forester, the company, and the owner of the neighboring property. The trial court awarded Plaintiff $67,180 in damages based on Defendants' timber harvest trespass. Plaintiff appealed, arguing that the court erred in its damages award and in declining to grant her motion to add the owner of the company as a party. The Supreme Court modified the judgment to double the district court's award of damages and affirmed the judgment as modified, holding (1) the district court erred by not doubling Plaintiff's damages as required by 14 Me. Rev. Stat. 7552(4)(A); and (2) the court did not abuse its discretion in denying Plaintiff's motion to add the owner as a party. View "Woodworth v. Gaddis" on Justia Law

This was the second appeal from a judgment of the superior court finding that Annabelle Robbins had breached implied covenants in her deed when she sold land to David and Vickie Lloyd. On appeal, Robbins' estate argued that the trial court erred in (1) finding that the six-year statute of limitations had not expired, (2) finding that the neighboring landowners never possessed or occupied the disputed land and that it misquoted the neighbor's testimony in its decision, and (3) awarding damages in the amount agreed to by the parties in a stipulated judgment because the court vacated that judgment in 2010. The Supreme Court affirmed, holding (1) the trial court properly found the statute of limitations had not expired at the time when the Lloyds filed their complaint alleging Robbins's breach; (2) the court's misstatement in its decision was harmless; and (3) the court did not abuse its discretion in awarding damages because the Estate failed to present any evidence that the stipulated damages were manifestly unjust and should be set aside. View "Lloyd v. Robbins" on Justia Law