Justia Maine Supreme Court Opinion Summaries

After a jury trial, Kenny Ouellette was convicted of reckless conduct. Ouellette appealed, arguing that the superior court erred in (1) declining to instruct the jury on his justification of self-defense to the charge of reckless conduct, and (2) failing to inform the jury of the parties' out-of-course resolution that resulted in a dismissal of a count of criminal mischief stemming from the same incident. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's instruction to the jury that it could not consider self-defense as to the charge of reckless conduct was erroneous, and (2) the error was not harmless. Remanded for a new trial. View "State v. Ouellette" on Justia Law

Christine Angell filed a complaint against Renald Hallee and the Roman Catholic Bishop of Portland, alleging that Hallee sexually abused her during her childhood while he was a priest. Hallee and the Bishop asserted the statute of limitations as an affirmative defense and moved for judgment on the pleadings. The superior court granted the motions and entered judgment in Hallee's and the Bishop's favor. The Bishop was later dismissed, and Angell appealed. The Supreme Court vacated the judgment of the superior court, holding that the court erred in imposing on Angell a burden to allege and prove that the statute of limitations was tolled while Hallee was absent from and resided out of state but was potentially amenable to service of process by means other than publication. View "Angell v. Hallee" on Justia Law

Following a jury trial, Jesse Guyette was convicted of unlawful possession of scheduled drugs. Guyette appealed, arguing that the superior court erred by admitting several statements at trial pursuant to the Me. R. Evid. 804(b)(3) exception to the hearsay rule for statements against penal interest. The Supreme Court vacated Guyette's conviction, holding (1) the trial court abused its discretion by admitting the out-of-court statements of a person who was not a codefendant at trial but whose statements implicated Guyette because the statements did not fall within the Rule 804(b)(3) hearsay exception; and (2) the court's error in admitting those statements was not harmless. View "State v. Guyette" on Justia Law

Jeffrey Buhrman, the sole trustee of the Clifton Pike Family Trust, a testamentary trust established under Clifton Pike's will, appealed the decision of the probate court granting the petition of the two adult children of Clifton and Doris Pike to combine the assets of Doris's estate into Clifton's trust, terminate both parents' trusts, and direct that the assets be distributed. At issue was whether a spendthrift provision precluded the termination of the trusts. The Supreme Court affirmed after noting that a trust may be terminated early when its purpose has been accomplished or when there is no good reason for the trust to continue, holding that Buhrman failed to meet his burden that the spendthrift provision was a material purpose of the trust. View "In re Pike Family Trusts" on Justia Law

Employee suffered a gradual injury while working for Employer. After Employee retired, he underwent spinal fusion surgery. Employee subsequently filed a petition for award. A Workers' Compensation Board hearing officer granted him the protection of the of the Workers' Compensation Act for his gradual injury but awarded no additional incapacity benefits. Employee appealed, arguing, among other things, that the hearing officer erred when determining that Employee did not rebut the retiree presumption in Me. Rev. Stat. 39-A with evidence that he was unable to perform suitable work for a discrete period of time after retirement. The Supreme Court vacated the decision in part, holding that the hearing officer's decision provided an inadequate basis for appellate review. Remanded for further proceedings. View "Downing v. Dep't of Transp." on Justia Law

Mark Cookson purchased two homeowner's insurance policies from Liberty Mutual, one to cover his primary residence in West Newfield and another to cover property in Acton, where he was constructing a house. Cookson would drive his tractor along public roads between the properties. Cookson's tractor was subsequently destroyed by fire. Cookson filed a claim for loss of the tractor, which Liberty Mutual denied based on a personal property exclusion in both policies. Cookson filed a complaint seeking, in part, a declaratory judgment that the Liberty Mutual policies provided coverage for his tractor. The superior court granted summary judgment in favor of Liberty Mutual, concluding that Cookson's policies excluded the tractor from loss coverage. The Supreme Court affirmed, holding (1) Cookson's tractor was not the type of vehicle that fell within the limited exception for "vehicles not subject to motor vehicle registration" to the otherwise broad personal property exclusion of all "motor vehicles or all other motorized land conveyances," and (2) Cookson's tractor was not the type a homeowner would commonly purchase and employ simply to service his or her residence. View "Cookson v. Liberty Mut. Fire Ins. Co." on Justia Law

This appeal involved six siblings and their mother. The parties participated in mediation that resulted in an agreement, which, among other things, divided Mother's real property. After disputes arose over the agreement, the probate court ordered arbitration pursuant to the agreement's arbitration clause. The arbitrator concluded that the agreement was enforceable and ordered the transfer of land necessary to effectuate it. Four of the sisters (Appellants) and the remaining siblings and mother (Appellees) then filed a series of motions. The superior court confirmed the arbitration award, denied a motion to vacate the award, denied a motion for judgment on the pleadings, and granted a motion to dismiss a complaint for declaratory judgment. The Supreme Court affirmed, holding that the superior court did not err in affirming the arbitrator's award and in concluding that the arbitrator and that the settlement agreement gave the arbitrator the authority to determine whether the agreement was valid and enforceable. View "Anderson v. Banks" on Justia Law

Raymond Cloutier appealed from a judgment entered in the district court granting Robin Turner's motion to enforce the child support provisions of a 1992 amended divorce judgment. The Supreme Court affirmed the judgment, holding (1) Turner had standing to bring the motion even though the children were above the ages of eighteen because, although the obligation to provide future support ends when the child reaches majority, liability for arrearages does not terminate then; (2) where child-support arrearages are considered money judgments and there is no statute of limitations for money judgments, Turner's claim of overdue child support was not time-barred; (3) the court's failure to apply the statute of limitations did not deprive Cloutier of his constitutional right of equal protection because Cloutier was not treated any differently than fathers who are subject to child support enforcement stemming from a paternity action; and (4) Cloutier failed to make the showing necessary to establish the defense of laches. View "Cloutier v. Turner" on Justia Law

Defendant was indicted for aggravated trafficking of scheduled drugs, unlawful trafficking in scheduled drugs, and illegal importation of scheduled drugs. Defendant moved to suppress incriminating statements he made to a Maine Drug Enforcement Agency (MDEA) agent while in the agent's custody and after Defendant had invoked his right to counsel in violation of the Fifth Amendment. The superior court granted Defendant's motion after applying Maryland v. Shatzer, concluding that the State had failed to prove that Defendant's waiver of his right to counsel was voluntary because the agent had resumed his questioning of Defendant just a few hours after Defendant had invoked his right to counsel, far less than the fourteen-day standard required by Shatzer. The Supreme Court vacated the superior court, holding that the court erred by evaluating the evidence and rendering its findings through the lens of the Shatzer fourteen-day standard and should have employed the analytical framework advanced in Edwards v. Arizona and Oregon v. Bradshaw in determining whether Defendant voluntarily reinitiated interrogation. Remanded for the court to reconsider the evidentiary record and to apply the Edwards and Bradshaw standards. View "State v. Knowlton" on Justia Law

Following a jury trial, Rory Holland was convicted of two counts of intentional or knowing murder and sentenced to two concurrent life sentences. The Supreme Court affirmed the judgment and sentences, holding (1) the trial court did not abuse its discretion when it refused to admit evidence of the victims' reputations for violence that was not known to Holland prior to the murders; (2) the trial court did not err in admitting a book containing the Maine Criminal Code into evidence where the evidence was not unfairly prejudicial; (3) the trial court properly denied Holland's motion in limine to permit statements from an earlier civil trial to be admitted into evidence to provide context for Holland's reaction to threats and violence; (4) there was sufficient evidence to disprove Holland's claim of self-defense; (5) the trial court did not err by allowing the State to reopen its case to present evidence regarding identification of Holland; and (6) the court did not abuse its discretion in imposing concurrent life sentences. View "State v. Holland" on Justia Law