Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of intentional and knowing murder. The trial court sentenced Defendant to thirty-five years in prison. Defendant appealed, arguing (1) the court erred in denying him a new trial based on the State's failure to produce exculpatory evidence, (2) the court violated the equal protection right of a juror removed from the panel given his inability to deliberate past 5:08 p.m. for religious reasons, and (3) there was insufficient evidence to support his conviction. The Supreme Court affirmed the judgment, holding (1) Defendant received a fair trial in this matter; (2) there was no disparate treatment of the juror, and therefore, the juror's equal protection rights were not violated; and (3) there was no error in the trial court's entry of the judgment of conviction or its sentencing analysis. View "State v. Carr" on Justia Law

Employee filed this action against Employer and her four individual supervisors (Supervisors), claiming whistleblower discrimination pursuant to the Whistleblowers' Protection Act (WPA) and the Maine Human Rights Act (MHRA) and sex discrimination pursuant to the MHRA. The superior court granted Supervisors' motion to dismiss, finding they could not be held individually liable pursuant to the WPA and the MHRA. The court then entered summary judgment in favor of Employer on all claims. Employee appealed, contending (1) summary judgment for Employer was improper because she presented a prima facie case of whistleblower discrimination and there remained material facts in dispute, and (2) the dismissal of her claims against Supervisors was improper. The Supreme Court affirmed with respect to the sex discrimination claim and the dismissal of Supervisors but vacated the judgment with respect to the whistleblower discrimination claim against Employer, holding (1) material facts remained in dispute regarding Employee's whistleblower claim; but (2) the WPA and MHRA do not provide for individual supervisor liability. View "Fuhrmann v. Staples the Office Superstore E., Inc." on Justia Law

Following a nonjury trial, Defendant was convicted of domestic violence assault. Defendant's sentence included a period of two years of probation with a requirement that he participate in a certified batterers' intervention program. Defendant contended that his sentence violated the Equal Protection clauses of the U.S. and Maine Constitutions because, he asserted, a woman convicted of the same crime could not be sentenced to a term of probation of more than one year. The Supreme Court vacated the sentence and remanded for additional proceedings because there was no factual record from which the Court could evaluate Defendant's and the State's arguments. View "State v. Mosher" on Justia Law

The Board of Licensure in Medicine revoked Petitioner's medical license. The superior court dismissed Petitioner's complaint seeking judicial review, concluding (1) it lacked subject matter jurisdiction to review the Board's decision because the district court had exclusive jurisdiction to review nonconsensual license-revocation orders pursuant to Me. Rev. Stat. 10, 8003(5); and (2) Petitioner's 42 U.S.C.S. 1983 claim should be dismissed because the Board members had authority to revoke her license and were immune from suit. The Supreme Court affirmed, holding (1) the superior court properly dismissed Petitioner's petition for review of the Board order revoking her license because the district court had exclusive jurisdiction in such matters; and (2) because the Board acted within its authority in revoking Petitioner's license and, on appeal, Petitioner did not otherwise assert a denial of her constitutional rights, Petitioner's section 1983 claim was properly dismissed. View "Michalowski v. Bd. of Licensure in Med." on Justia Law

Defendant appealed from a judgment of conviction of one count of murder and one count of manslaughter entered in the trial court following a jury trial. Defendant argued that the trial court erred in denying his motion to suppress a confession, other statements, and physical evidence found as a result of the statements. The Supreme Court affirmed the judgment, holding that the trial court did not err in (1) finding Defendant was not in custody during the first interrogation; (2) failing to suppress Defendant's post-warning statements because the detectives' actions did not reflect a deliberate strategy to use "Miranda-in-the-middle," a two-step interrogation procedure; and (3) concluding that the State proved beyond a reasonable doubt that Defendant's post-warning statements were voluntary in light of the totality of the circumstances. View "State v. Nightingale" on Justia Law

Jeffrey Stephan was a GMAC Mortgage employee who signed summary judgment affidavits on behalf of GMAC in foreclosure proceedings instituted in Maine. The notarization on the summary judgment documents falsely stated that Stephan personally appeared and swore before the notary, when he did not. The U.S. District Court for the District of Maine certified the following question of state law to the Maine Supreme Court: "Is Maine's common law judicial proceedings privilege an available defense to both legal and equitable claims brought under the Maine Unfair Trade Practices Act based upon statements made in court filings of affidavits and certifications in state judicial foreclosure proceedings?" The Supreme Court declined to answer the certified question, where (1) if the Court answered the question in the affirmative, then the claim would be immediately and summarily dismissed even though the facts may have established that the privilege was not available to the defendant under any circumstances; and (2) if the Court answered the question in the negative, it would render a broad pronouncement of law that would have no application to this case if a threshold issue produced the same result - namely, that the judicial proceedings privilege was simply unavailable on these particular facts. View "Bradbury v. GMAC Mortgage, LLC" on Justia Law

Defendant was charged with the murder of her estranged husband. Following a jury trial, Defendant was found guilty of attempted murder, elevated aggravated assault, and false public alarm or report. Defendant appealed, asserting that the trial court made several evidentiary errors and that improper statements made by the prosecutor during the trial constituted prosecutorial misconduct that deprived her of a fair trial. The Supreme Court concluded that no evidentiary errors occurred and focused its discussion on Defendant's assertions of prosecutorial misconduct. The Court affirmed the judgment, holding that any prosecutorial misconduct, even considered cumulatively, did not affect the jury's verdict, and therefore, Defendant received a fair trial. View "State v. Dolloff" on Justia Law

Defendant appealed from a judgment of conviction entered in the trial court finding him guilty of four counts of criminal threatening with a dangerous weapon, eleven counts of criminal restraint with a dangerous weapon, twenty-two counts of kidnapping, one count of burglary, and one count of criminal restraint. The Supreme Court affirmed, holding (1) Defendant was not denied his right to speedy trial; (2) Defendant was not denied his right to self-representation; (3) the jury instructions accurately and fairly informed the jury in all necessary aspects of the law; (4) the court did not err by not dismissing the kidnapping charge; (5) there was sufficient evidence for the jury to find Defendant held the kidnapping victims for a "substantial period of time"; and (6) the court properly imposed consecutive sentences. View "State v. Hofland" on Justia Law

Brockway-Smith Company and MMTA Workers' Compensation Trust appealed from a decision of a Workers' Compensation Board hearing officer awarding incapacity benefits to Richard Graves for a 2003 work-related injury to his left shoulder. Brockway-Smith contended that Graves's claim for the 2003 injury was barred for failure to file it within the six-year limitations period in 39-A Me. Rev. Stat. The Supreme Court was asked to decide whether that six-year period was tolled until the employer filed a first report of injury with the Workers' Compensation Board, even though at the time of the injury the employer was not required to file a first report pursuant to 39-A Me. Rev. Stat, 303. The Supreme Court affirmed the hearing officer's decision, holding that the limitations period did not begin to run until the first report was filed. View "Graves v. Brockway-Smith Co." on Justia Law

The parents of L.E. appealed from a judgment of the county probate court terminating their parental rights. The mother challenged the sufficiency of the evidence terminating her rights, and both parents argued that the court erred in failing to order attempts at rehabilitation and reunification prior to granting the petition for termination. The Supreme Court affirmed the judgment, holding that the record was sufficient to establish by clear and convincing evidence that both parents were unfit, and that it was in the best interest of L.E. for the court to terminate parental rights and grant the adoption petition. View "In re Adoption of L.E." on Justia Law