Justia Maine Supreme Court Opinion Summaries

Defendant pleaded guilty to operating under the influence. Defendant moved to suppress all evidence obtained from the stop of his vehicle for lack of reasonable articulable suspicion. The trial court agreed that the police trooper, who followed Defendant's car into a business park and interacted with Defendant after he stopped his vehicle, lacked the required reasonable articulable suspicion. The Supreme Court vacated the portion of the trial court's decision granting Defendant's motion to suppress, holding that the lower court erred in determining that the trooper seized Defendant by following him into the park, as Defendant was not subject to physical force or show of authority. Remanded. View "State v. Collier" on Justia Law

Following a jury trial, Defendant was convicted of one count of arson. The Supreme Court affirmed the judgment of conviction, holding (1) the indictment and jury verdict did not deprive Defendant of his constitutional right to be free of double jeopardy because the trial court consolidated two separate counts of arson based on one criminal act identified in the indictment and jury verdict and sentenced Defendant for only one count of arson; and (2) under the circumstances, the trial court did not deprive Defendant of his Sixth Amendment right to counsel when it overruled Defendant's objection to the testimony of an anticipating defense witness who decided, mid-trial, to testify for the prosecution in exchange for a promise of immunity. View "State v. Bellavance" on Justia Law

After Stepmother and Father separated, Father's son, Stepmother's stepson (Stepson) continued to live with Stepmother. Stepmother subsequently filed a protection from abuse complaint against Father on behalf of herself, two of her biological children, and Stepson. Stepmother also petitioned for full guardianship of Stepson. Thereafter, Stepmother requested temporary parental rights and responsibilities for Stepson at the protection and abuse hearing. The district court awarded protection to all four petitioners but denied Stepmother's request for temporary parental rights and responsibilities for Stepson. The probate court then awarded Stepmother full guardianship of Stepson. The Supreme Court (1) vacated the portion of the trial court's judgment denying temporary parental rights and responsibilities to Stepmother, holding that the protection from abuse statute permits the court to award temporary parental rights to a stepparent, and the award would not have violated Father's due process rights; and (2) otherwise affirmed. View "Sparks v. Sparks" on Justia Law

The Department of Health and Human Services filed a child protection petition against D.P.'s parents, alleging that the parents placed D.P. in jeopardy. Mother filed a petition to terminate her own parental rights without a jeopardy hearing. In the petition, Mother agreed to a finding of jeopardy based on her substance abuse but sought to avoid a jeopardy hearing involving evidence of her sexual abuse of D.P. The court dismissed mother's termination petition, concluding that Mother did not have a statutory or constitutional right to petition to terminate her own parental rights or to forgo a full jeopardy hearing. After a jeopardy hearing, the court found jeopardy as to both parents based on domestic violence, abandonment, and sexual abuse of D.P. The Supreme Court affirmed, holding that the court did not err in holding the jeopardy hearing despite Mother's desire to terminate her parental rights on grounds of her own choosing, as (1) Mother was not statutorily authorized to petition to terminate her own parental rights; and (2) the lack of such statutory authority did not violate the U.S. Constitution. View "In re D.P." on Justia Law

Defendants installed video surveillance cameras at the entrance to an easement crossing their property. Members of a subdivision who benefitted from the easement (Plaintiffs) filed an action for a declaratory judgment and to enjoin Defendants from obstructing their easement rights. Plaintiffs relied on a 2006 settlement to support their position that Defendants were prohibited from installing the cameras. The trial court concluded that Defendants' video surveillance cameras constituted an unreasonable interference with the easement. The Supreme Court vacated the judgment of the superior court, holding (1) the 2006 settlement was relevant evidence to the reasonableness of the cameras, although it was not binding as between the parties to this suit, and the trial court did not err by considering that agreement because its terms provided evidence of the need for injunctive relief; and (2) the placement of the video cameras at issue here did not unreasonably interfere with the access easement benefitting Plaintiffs, nor did the cameras violate the non-disturbance clause in the settlement. Remanded for entry of judgment in favor of Defendants on the video camera issue. View "Flaherty v. Muther" on Justia Law

After a jury trial, Defendant was found guilty of burglary and theft by unauthorized taking or transfer for taking building materials worth more than $1,000. Defendant's adult son had told the police that he helped Defendant take the materials, but during the trial, he asserted his Fifth Amendment privilege against self-incrimination and refused to testify. On appeal, Defendant contended that the trial court erred when it admitted redacted versions of two statements his son made earlier to the police that incriminated both Defendant and his son. The Supreme Court vacated the judgment of conviction, holding that the trial court erred in admitting the statements of Defendant's son based both on the Rules of Evidence and the U.S. Constitution, and the error was not harmless. Remanded. View "State v. Larsen" on Justia Law

Defendant operated a returnable bottle redemption center. Defendant was convicted of theft by deception for turning over empty beverage containers that were not from beverages purchased in Maine and accepting deposit refunds and handling fees from Maine beverage distributors for those containers. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the conviction; (2) the trial court did not err in admitting evidence regarding bad acts committed outside the time alleged in the charging instrument; (3) a certain tactic employed by the prosecutor in the case amounted to prosecutorial error, but the error did not prejudice Defendant; and (5) the trial court did not err in failing to give requested jury instructions. View "State v. Woodard" on Justia Law

While working at Devereux Marine, Employee was electrocuted when the mast he was lowering came into contact with an overhead high-voltage power line owned by Central Maine Power Company (CMP). Employee received workers' compensation benefits through Devereux and separately sued CMP for negligence. The court awarded Employee $4,890,631 in damages. After paying the judgment, CMP brought this claim for indemnification against Devereux. Accompanying CMP's complaint was a motion for ex parte real estate attachment. The business and consumer docket denied CMP's motion for attachment, interpreting the Maine Overhead High-voltage Line Safety Act as creating a statutory right of contribution as opposed to a right to indemnification. The Supreme Court vacated the denial of the motion to attach, holding that full indemnification from an employer is required when (1) an employee is injured after bringing materials into contact with an overhead high-voltage power line; (2) the employer is determined to have violated the Act; and (3) the owner of the high-voltage line becomes liable to the employee. Remanded. View "Cent. Me. Power Co. v. Devereux Marine, Inc." on Justia Law

Plaintiff was employed by a Hospital for nineteen years. In 2009, Plaintiff was deposed in connection with a wrongful death lawsuit against the Hospital. The day after Plaintiff signed her deposition transcript, the Hospital terminated Plaintiff's employment on the ground that a medical record entry Plaintiff described in her deposition constituted a falsification of a patient medical record. Plaintiff filed a complaint against the Hospital, alleging that it violated Me. Rev. Stat. 26, 833(1)(C) because it discharged her in retaliation for her deposition testimony in the wrongful death lawsuit against the Hospital. The superior court granted summary judgment in favor of Hospital. The Supreme Court vacated the judgment, holding that Plaintiff presented sufficient evidence to create a genuine issue of material fact regarding whether her deposition was a substantial factor motivating her dismissal. View "Trott v. H.D. Goodall Hosp." on Justia Law

Employee suffered an injury to his left hand while working for Employer. Later, Employee's left index finger had to be amputated. Employee subsequently filed a petition for specific loss benefits. The parties agreed Employee was entitled to specific loss benefits because of the amputation for a period of thirty-eight weeks. At issue was whether Employer was entitled to an offset for the incapacity benefits it paid before the amputation. The Workers' Compensation Board granted the petition for specific loss benefits and determined that Employer was allowed to offset the incapacity benefits paid before the amputation. The Supreme Court vacated the Board's decision, holding that Employer was not entitled to offset the incapacity benefits paid during the months after Employee's initial injury but before the amputation of his finger. View "Scott v. Fraser Papers, Inc. " on Justia Law