Justia Maine Supreme Court Opinion Summaries

The case revolves around Jessica A. Williams, who was convicted for depraved indifference murder of her son, Maddox Williams. Maddox was born to Jessica and his father in 2018, and lived with Jessica after his father's arrest in 2020. From October to December 2020, Maddox occasionally had bruises on his body when he came from Jessica's care. In March 2021, Jessica assumed sole custody of Maddox. During her custody, Maddox had multiple injuries, which Jessica attributed to his clumsiness. In June 2021, Maddox was taken to the hospital where he lost consciousness and was pronounced dead. Jessica did not appear to react strongly to Maddox’s death and left the ER shortly after his death. She was later arrested by the police.The trial court had previously heard the case, where the State sought to introduce evidence of prior bad acts by Jessica. Over Jessica's objection, the court granted the motion. At the close of the evidence, Jessica moved for a judgment of acquittal, which the court denied. The jury subsequently returned a verdict of guilty and Jessica was sentenced to forty-seven years in the Department of Corrections.In the Maine Supreme Judicial Court, Jessica appealed her conviction, arguing that the trial court erred in admitting evidence related to a prior bad act, admitting evidence regarding her lack of communication with police officers, and denying her motion for a judgment of acquittal. She also argued that the cumulative effect of all three issues constituted a violation of her due process rights. The court disagreed with her contentions and affirmed the judgment. View "State v. Williams" on Justia Law

The case involves a dispute between Peter M. Beckerman and Ricky and Monica Conant over a deeded right-of-way over the Conants' driveway. The parties own abutting waterfront properties in Rome, Maine. Beckerman's property, the Conant property, and a third property, formerly known as the Bruce Pooler lot, are connected to South Crane Lane by a horseshoe-shaped driveway that runs across all three properties. Beckerman has a deeded right-of-way over the Conants' driveway to access South Crane Lane.Previously, Beckerman had filed an action against the Poolers, previous owners of the other two lots, to establish the location of the common boundaries of the three lots. The parties settled the action at mediation, resulting in a consent order in 2002 that established the current boundaries of the three properties. As part of the settlement, Beckerman secured a right-of-way over the driveway on the Bruce Pooler lot in order to access South Crane Lane.In 2012, Beckerman filed a post-judgment motion for contempt, alleging that the Conants were in contempt of the 2002 consent judgment by impeding his use of the right-of-way over the Conant lot. The court denied Beckerman’s motion for contempt because the language of the consent order was ambiguous. Beckerman appealed and the court affirmed the denial of the contempt but vacated the portion of the court’s determination regarding whether Beckerman had an easement by deed.On remand, after a three-day bench trial, the court entered a judgment declaring that Beckerman has a deeded right-of-way over the Conants’ driveway and enjoining the Conants from interfering with that right-of-way. The Conants appealed the judgment.The Maine Supreme Judicial Court affirmed the judgment. The court found that the language of the 2016 judgment was clear and specific, and the Superior Court did not abuse its discretion in finding the Conants in contempt. The court also found that the Superior Court did not err in concluding that Beckerman may use the entire paved driveway as needed to access his property. The court further held that the doctrine of claim preclusion did not apply in this instance as there was no valid final judgment entered with respect to Beckerman’s August 2016 motion for contempt. Lastly, the court held that the Superior Court was within its discretion to award Beckerman attorney fees under M.R. Civ. P. 66(d)(3)(C). View "Beckerman v. Conant" on Justia Law

The case involves Jaquille J. Coleman, who was convicted for murder and sentenced to forty-seven years in prison. The key facts of the case revolve around the murder of Natasha Morgan, Coleman's former partner and mother of his child. After their relationship ended, Coleman pursued Morgan, leading to an incident where he shot her in front of her mother. The police found bullets and shell casings at the scene and in the car Coleman had been driving, which were confirmed to have been fired from the same gun. Coleman was later found in Mississippi and extradited to Maine.Prior to the Supreme Judicial Court of Maine, Coleman had been convicted by the trial court after a jury trial. He appealed his conviction and sentence, arguing that the trial court had erred in admitting evidence of the victim’s state of mind, denying his motion for a mistrial based on a prosecutorial comment, and considering his failure to express remorse as an aggravating factor in his sentencing.The Supreme Judicial Court of Maine affirmed the lower court's decision. The court rejected Coleman's arguments, ruling that the evidence of the victim’s state of mind was admissible as it was relevant to show Coleman’s motive. The court also found that the prosecutor's comment did not shift the burden of proof to Coleman, and the court's immediate instruction to the jury clarified the burden of proof. Lastly, the court held that the sentencing court properly considered the substance of Coleman’s allocution in assessing lack of remorse as an aggravating factor. View "State v. Coleman" on Justia Law

This case involves a dispute over an easement, a right to cross or otherwise use someone else's land for a specified purpose. The plaintiffs, Kinderhaus North LLC, Prime Properties ME LLC, and Karen and Brian Fullerton (collectively, the Fullertons), own four lots in a subdivision and have an expressly deeded easement across a lot owned by the defendants, Karl and Stephanie Nicolas. The Fullertons claimed that the Nicolases had obstructed their easement by installing a granite lamp post and several trees. The Fullertons removed some of these trees, leading to a dispute over whether they had the right to do so and whether they had committed a timber trespass by cutting down the trees.The Business and Consumer Docket found that the Fullertons had an expressly deeded easement across the Nicolases' property, but that the easement was ambiguous as to its scope and purpose. The court found that the Fullertons did not have an unlimited right to use the full length and width of the easement as a driveway, and that the trees and lamp post did not prevent vehicle or pedestrian passage within the easement. The court also found that Karen Fullerton had committed a timber trespass by intentionally cutting down four trees within the easement, and awarded the Nicolases damages for this trespass. The court further found that Karen Fullerton had committed a common law trespass by entering the Nicolases' property without their consent, and awarded nominal and punitive damages for this trespass. The court granted summary judgment for the Nicolases on the Fullertons' slander of title and abuse of process claims.The Fullertons appealed, and the Maine Supreme Judicial Court vacated the lower court's judgment on several issues and remanded for further findings. The court held that the Fullertons had the right to remove obstacles within their easement, and that Karen Fullerton was therefore an "owner" within the meaning of the timber trespass statute. The court also held that punitive damages may be awarded in common law trespass cases where nominal damages are awarded, but remanded for the lower court to make further findings under the guidelines established by the U.S. Supreme Court for determining punitive damages. The court affirmed the lower court's judgment in all other respects. View "Kinderhaus North LLC v. Nicols" on Justia Law

The case involves Richard Peters, who was convicted for hunting a deer after having killed one and unlawful possession of wild animals. Peters appealed his conviction, challenging the denial of his motions for a mistrial, the sufficiency of the State’s bill of particulars, and the jury instructions. He also argued that double jeopardy protections barred his conviction on the charge of unlawful possession of wild animals.Previously, the trial court had stayed Peters’s sentence to require him to report to the Androscoggin County Sheriff’s alternative sentencing program. However, after Peters appealed, the court amended the stay to require him to surrender to the Penobscot County Sheriff to serve his sentence, interpreting M.R.U. Crim. P. 38(d) strictly.The Maine Supreme Judicial Court disagreed with Peters's contentions and affirmed the judgment. However, the court agreed with Peters that the trial court retained the authority to order the original stay and remanded the case for the trial court to consider whether to reinstate it. The court clarified that the trial court, having determined that the alternative sentencing program was appropriate, retained the discretion to order a stay to effectuate that determination. View "State of Maine v. Peters" on Justia Law

This case involves a dispute over a contract zone agreement that would have allowed development on a property in Saco, Maine. The property owners, Amarjit Singh Dhillon and Ajinder Kaur, appealed from a lower court's grant of partial summary judgment to Michael Dahlem, who owns neighboring property and challenged the contract zone agreement. Dahlem cross-appealed from the court's dismissal of his Rule 80B appeal and denial of his motion to reconsider that dismissal, and from the court's denial of summary judgment on two counts in his complaint.The lower court had granted summary judgment to Dahlem on several counts, declaring that the 2017 agreement became null and void in 2019 and thereafter could not be amended, was invalid and unlawful for noncompliance with the City’s contract zoning ordinance, and was inconsistent with Maine’s Mandatory Shoreland Zoning statute and therefore preempted and invalid. The court denied summary judgment to all parties on the count of whether the 2021 agreement was compatible with the City’s comprehensive plan.The Maine Supreme Judicial Court affirmed the lower court's decision in all respects and dismissed Dahlem’s cross-appeal as moot. The court held that Dahlem properly challenged the 2021 agreement by asserting claims for declaratory relief, that the 2017 agreement became null and void on November 20, 2019, and could not thereafter be amended, that the 2021 agreement was invalid and unlawful under the City’s contract zoning ordinance, and that the 2021 agreement was preempted by the Mandatory Shoreland Zoning provisions. View "Dahlem v. City of Saco" on Justia Law

Michael G. Saucier was convicted by a jury in the trial court (Aroostook County, Nelson, J.) for one count of gross sexual assault (Class A), one count of unlawful sexual contact (Class B), and one count of unlawful sexual contact (Class C). The charges stemmed from incidents that occurred when Saucier was the stepfather of the victim. The key issue was whether there was sufficient evidence to prove the victim's age at the time of the offenses, which was a crucial element for each of the charges.The trial court denied Saucier's motion for a judgment of acquittal on all counts, except for one count of unlawful sexual contact (Class B) due to insufficient evidence to prove that the victim was under twelve years old when the offense occurred. The jury found Saucier guilty on the remaining three counts. Saucier was sentenced to twenty-two years for the Class A offense, with nine years for the Class B offense and five years for the Class C offense, all to be served concurrently.On appeal, the Maine Supreme Judicial Court found that the evidence regarding the victim's age was sufficient to sustain a conviction on the Class C offense but not on the Class A and B offenses. The court noted that the State failed to provide evidence to identify the victim's date of birth or her age during the relevant time period. The court concluded that while the jury could reasonably infer that the victim was under fourteen during her time in Exeter, no such inference could be made that she was under the age of twelve. Consequently, the court vacated the convictions on the Class A and B offenses, affirmed the conviction on the Class C offense, and remanded the case for resentencing on the Class C offense. View "State v. Saucier" on Justia Law

The case involves a group of plaintiffs, led by Chris Calnan, who challenged a rule implemented by Maine Emergency Medical Services (Maine EMS) requiring emergency medical service (EMS) workers to be fully vaccinated against COVID-19 and influenza. The plaintiffs sought a declaratory judgment that Maine EMS lacked statutory authority to implement such a rule.The Superior Court (Kennebec County) dismissed the plaintiffs' complaint. The court concluded that the plaintiffs had named the correct defendants, that it had jurisdiction to consider the challenge to the rulemaking, and that the EMS Board acted within its authority in implementing the immunization rule. The court also dismissed the plaintiffs' motion for summary judgment as moot.On appeal, the Maine Supreme Judicial Court affirmed the lower court's decision. The court found that the EMS Board did not exceed its statutory authority in issuing the immunization rule. The court also concluded that the rule aligns with the purpose of the Maine Emergency Medical Services Act of 1982, which is to ensure optimum patient care and the safe handling and transportation of patients. Lastly, the court determined that the EMS Board followed the applicable rulemaking process for the promulgation of the immunization rule. View "Calnan v. Hurley" on Justia Law

The case involves Roger Ouellette, who was convicted of Operating Under the Influence (OUI) following a police stop in his driveway. The police officer had observed Ouellette's vehicle crossing the center line of the road, which led the officer to suspect a violation of traffic laws. Ouellette entered a conditional guilty plea after his motion to suppress evidence obtained from the stop was denied by the trial court.The trial court found that the officer had reasonable suspicion to stop Ouellette due to his observed traffic violation. Ouellette argued that the stop was unjustified as the officer lacked reasonable suspicion of wrongdoing. However, the court determined that the stop was supported by reasonable articulable suspicion that Ouellette had violated the motor vehicle statute requiring vehicles to be operated within a single lane.On appeal, Ouellette argued that the stop was an unreasonable seizure under the Fourth Amendment because it occurred within the curtilage of his home without a warrant and without any applicable exception to the warrant requirement. The Maine Supreme Judicial Court affirmed the lower court's decision, concluding that the court's failure to grant Ouellette’s motion on that ground did not constitute obvious error and that the stop was justified based on reasonable suspicion. The court also found that Ouellette's argument regarding the stop occurring within the curtilage of his home was unpreserved and did not amount to obvious error. View "State of Maine v. Ouellette" on Justia Law

The case revolves around a dispute between MMG Insurance Company (MMG) and the Estate of Philip J. Greenlaw. The dispute arose after the death of Philip Greenlaw, who died while wrestling with his friend, Joseph McNeely. Prior to the incident, McNeely, who operated a landscaping business, had visited Greenlaw's house to provide an estimate for a landscaping project. The visit was part of an informal social gathering where business-related topics were often discussed. After the incident, the Estate filed a wrongful death action against McNeely. MMG, which had issued a business insurance policy to McNeely, sought a declaratory judgment that it had no duty to indemnify McNeely in the wrongful death action.The Superior Court (Cumberland County) granted MMG's motion for summary judgment, determining that McNeely was not covered as an insured under MMG’s business insurance policy because his actions while wrestling with Greenlaw were not related to the conduct of his landscaping business. The Estate appealed this decision, arguing that there were triable issues of fact regarding whether Greenlaw’s death occurred with respect to the conduct of McNeely’s business.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court found that the insurance policy provision was unambiguous and that McNeely was covered as an insured only with respect to the conduct of his business. The court also agreed with the lower court's determination that there was no genuine issue of material fact and that McNeely’s actions while wrestling with Greenlaw were not related to the conduct of his landscaping business. Despite the business-related discussions and activities that occurred earlier in the evening, the court concluded that McNeely's wrestling actions were not taken with respect to the conduct of his business. View "MMG Insurance Company v. Estate of Greenlaw" on Justia Law