Justia Maine Supreme Court Opinion Summaries

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In this dispute concerning the rights and obligations of Appellants pursuant to a pipeline capacity agreement they had with Appellee, the Supreme Judicial Court affirmed the judgment of the business and consumer docket denying Appellants’ application to vacate several arbitration awards pursuant to Me. Rev. Stat. 14, 5938(1)(C). The court held that, contrary to Appellants’ argument on appeal, the arbitrator did not exceed his authority pursuant to the statute because the arbitration awards did not directly contradict the language of the agreement or constitute a manifest disregard for the terms of the agreement. View "XPress Natural Gas, LLC v. Woodland Pulp, LLC" on Justia Law

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Wells Fargo appealed from the district court’s judgment dismissing its foreclosure complaint against Defendant as a sanction for pretrial misconduct. After a nontestimonial hearing, the court ordered the action dismissed with prejudice. Wells Fargo moved to alter or amend the judgment to provide for a dismissal without prejudice. The district court denied the motion and maintained the dismissal with prejudice. The Supreme Judicial Court remanded the case to the district court to conduct a proceeding that comports with the process recently articulated in Green Tree Servicing, LLC v. Cope, ___ A.3d ___, issued on April 11, 2017, holding that the process used by the trial court did not entirely follow the procedural steps that a court should take before imposing the sanction of dismissal with prejudice. View "Wells Fargo Bank, N.A. v. Welch-Gallant" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder following a jury trial. Defendant argued that the trial court erred in admitting text messages found in the victim’s cell phone, erred in admitting three photographs of the crime scene in which the victim’s body was visible, and erred by giving the jury what he alleged was a confusing and legally flawed self-defense instruction. The Supreme Judicial Court held that the trial court (1) did not err in admitting the texts because they were relevant, and the State satisfied Me. R. Crim. P. 901’s threshold requirement; (2) informed the jury correctly and fairly in all necessary respects of the governing law, and the instructions were legally accurate; and (3) did not obviously err in admitting the three photographs depicting relevant evidence in this case. View "State v. Marquis" on Justia Law

Posted in: Criminal Law
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The district court granted Defendant’s motion to suppress evidence that resulted in a criminal complaint charging Defendant with operating under the influence, concluding that a police officer violated the Fourth Amendment when he ordered Defendant to leave his house in order to complete a traffic stop due to defective license plate lights. The district court concluded (1) the officer did not have probable cause to suspect any criminal activity, and no exigent circumstances existed when he ordered Defendant to exit his house; and (2) the officer’s verbal order to come outside amounted to an unlawful seizure of Defendant. The Supreme Judicial Court vacated the order of suppression, holding (1) the police officer had probable cause to arrest Defendant for the crime of failure to stop his vehicle on request or signal of a uniformed law enforcement officer and pursued him immediately and continuously from the scene of the crime into the curtilage of his home; and (2) therefore, the seizure of Defendant did not amount to unlawful seizure or arrest. View "State v. Blier" on Justia Law

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The Supreme Judicial Court vacated an order entered by the trial court suppressing evidence seized from Defendant, his vehicle, and his residence after the court concluded that the warrant authorizing the search and seizure of the evidence was not supported by probable cause. On appeal, the State argued that the information presented in the warrant affidavit was sufficient for the warrant judge to find that there was probable cause that evidence of a crime would be found in Defendant’s car, in his home, and on his person. The Supreme Judicial Court agreed, holding that the warrant affidavit provided the necessary substantial basis for the warrant judge’s finding of probable cause. View "State v. Mariner" on Justia Law

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Husband appealed from a district court judgment awarding child support and primary residence of the parties’ children to Mother. The Supreme Judicial Court vacated the portion of the judgment related to the health insurance component of Husband’s child support obligation and affirmed the judgment in all other respects, holding (1) the district court did not err by awarding primary residence of the children to Mother; but (2) the district court committed clear error in its factual findings regarding the calculation of Father’s obligation to pay for the children’s health insurance. View "Pyle v. Pyle" on Justia Law

Posted in: Family Law
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After this case was returned from the federal courts to a Florida superior court’s jurisdiction, only Plaintiff’s claims for defamation and false light invasion of privacy remained. Plaintiff, a town official for the Town of Raymond, filed suit against a town selectman, alleging Defendant had made various false statements to the sheriff’s office about Plaintiff’s alcohol for the purpose of humiliating and harassing Plaintiff. The superior court granted Defendant’s special motion to dismiss both remaining causes of action on anti-SLAPP grounds. The Supreme Judicial Court affirmed, holding that Plaintiff failed, as a matter of law, to meet his prima facie burden on opposing Defendant’s special motion to dismiss, and therefore, the superior court correctly dismissed the remaining claims. View "Desjardins v. Reynolds" on Justia Law

Posted in: Personal Injury
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Appellant appealed from the superior court’s post-judgment order awarding her attorney fees in the amount of $8,000 after a jury found Appellee liable for illegal eviction and wrongful use of civil proceedings. Appellant had requested nearly $60,000 in attorney fees. The Supreme Court affirmed, holding that the superior court did not apply an improper standard in evaluating Appellant’s request for attorney fees and that the court’s ultimate fee award was not an abuse of discretion. The court reviewed the award of attorney fees pursuant to Me. Rev. Stat. 14, 6014(2)(B) for an abuse of discretion and according the trial court substantial deference. View "Sands v. Thomas" on Justia Law

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At issue here was the application of Me. Rev. Stat. 22, 4036(1-A) to preexisting parental rights orders. Section 4036(1-A) authorizes a court that has made a finding of jeopardy in a title 22 child protection proceeding to enter an order awarding parental rights and responsibilities if the court determines the order will protect the child from jeopardy and is in the child’s best interest. In this case, the trial court did not direct the opening of a family matters case as directed by section 4036(1-A)(A) but instead amended the parental rights and responsibilities order that had been issued in the parties’ previous divorce judgment that was in effect at the time of the jeopardy hearing. The trial dismissed the child protection action and awarded sole parental rights over the child to Mother by amending the preexisting parental rights and responsibilities order. The court further made a specific finding that Father created circumstances of jeopardy for his child. The Supreme Judicial Court affirmed the jeopardy order and the amended parental rights and responsibilities order, holding that the trial court did not abuse its discretion in reaching its ultimate conclusion. View "In re Paige L." on Justia Law

Posted in: Family Law
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The Maine Supreme Judicial Court upheld the termination of father’s parental rights, 22 M.R.S. 4055(1)(B)(2) as in the best interests of the children. The lower court found by clear and convincing evidence that Father was unable to protect the children from jeopardy or to take responsibility for them within a time reasonably calculated to meet their needs. The court noted that: the children had been neglected in the care of their mother; Father’s partner has “a serious child protection history; at the time of their October 2014 removal from mother's custody, Father had not seen the children since January 2014; the children had been in foster care for two years since removal from their mother and have done well in foster care; Father did not understand the medical needs of the children: and Father did not make progress on a reunification plan or get mental health treatment required by the plan for his depression, PTSD, and ADHD issues. The guardian ad litem had recommended termination, noting that the children have a high-level of needs and need permanency. View "In re Kayleigh P." on Justia Law

Posted in: Family Law