Justia Maine Supreme Court Opinion Summaries

In this divorce action, Husband appealed from the divorce judgment and the judgment denying his motions for a new trial and for relief from the divorce judgment, arguing (1) the district court should have conducted a new trial because he did not attend the final hearing that resulted in the divorce judgment, and (2) the evidence did was not sufficient to demonstrate his ability to pay spousal support in the amount of $6,000 per month. The Supreme Court affirmed, holding (1) the two essential elements of due process of law - notice and the opportunity to be heard - were provided in relation to the final hearing, though Husband elected not to heed the notices supplied to him and failed to take advantage of any of his opportunities to be heard; and (2) the court’s award of support was within the bounds of reasonableness. View "Haskell v. Haskell" on Justia Law

The Supreme Judicial Court held that the trial court did not err in refusing to instruct the jury during Defendant’s criminal trial that the jury needed to find that Defendant had acted intentionally or knowingly in order to find him guilty of possessing a loaded firearm in a motor vehicle and unlawfully driving deer. The Court concluded (1) the firearm offense is a strict liability crime and, therefore, no mens rea instruction was necessary; and (2) the crime of driving deer is not a strict liability crime and contains a mens rea component, but because the trial court’s instructions adequately and correctly conveyed the elements of both crimes to the jury, the trial court did not err in refusing Defendant’s jury instruction request. View "State v. Siracusa" on Justia Law

The Supreme Judicial Court held that the trial court did not err in excluding one of Defendant’s statements from a recorded interview with police that was admitted at Defendant’s jury trial, holding that the court’s exclusion of the statement that the victim “likes it rough” was not prejudicial to Defendant’s defense and did not violate his right to due process. In addition, the Court was unpersuaded by Defendant’s contention that the statement was admissible pursuant to Me. R. Crim. P. 412(b). The Court thus affirmed Defendant’s judgment of conviction for gross sexual assault, assault, domestic violence criminal threatening, and criminal restraint. View "State v. Grindle" on Justia Law

The Supreme Judicial Court affirmed the termination of Mother’s parental rights to Ashlyn pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2), holding that the evidence was sufficient to support the judgment and the district court’s discretionary determination of Ashlyn’s best interest. Ashlyn, who was thirteen months old at the time of the termination hearing, had lived with her maternal grandparents and her older sister since she was two days old. The Court concluded that there was sufficient evidence to support the district court’s findings, by clear and convincing evidence, of at least one ground of parental unfitness and that termination of Mother’s parental rights was in Ashlyn’s best interest. View "In re Ashlyn L." on Justia Law

The Supreme Judicial Court affirmed the termination of Father’s parental rights to his child. The Department of Health and Human Services filed a petition seeking to terminate Father’s parental rights to his child more than twenty-two months after the child entered Department custody. The district court terminated Father’s parental rights to the child pursuant to Me. Rev. Stat. 22, 4055(1)(A), finding, by clear and convincing evidence, that Father was unfit to parent the child on three grounds and that termination of Father’s parental rights was in the child’s best interest. The Supreme Court held that the district court’s unfitness and best interest determinations constituted neither clear error nor an abuse of discretion. View "In re Isabelle W." on Justia Law

The Supreme Judicial Court affirmed the district court’s dismissal of Brian Danielson’s motion for relief from a post-divorce contempt judgment that had been entered against him. Danielson and Yi Peng were divorced through a judgment establishing that the parties would share parental rights and responsibilities of their minor daughter. Peng later moved for contempt on the ground that Danielson was depriving her of contact with the child. The court found Danielson in contempt. The Supreme Judicial Court affirmed. Danielson subsequently challenged the judgment finding him in contempt, arguing that the trial court lacked jurisdiction to decide the contempt motion because it had granted a change in venue before holding the contempt hearing. The district court dismissed Danielson’s motion for relief from the contempt judgment as moot. The Supreme Judicial Court affirmed, holding that the trial court did not err in determining that Danielson’s motion for relief raised no real and substantial controversy. View "Danielson v. Peng" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for operating under the influence, holding that the trial court did not err in concluding that Defendant’s defense that his operation of a motor vehicle was involuntary did not apply to the facts of this case. Specifically, the Court held (1) the trial court erred in concluding that the involuntariness defense can never apply to strict liability crimes; but (2) the court did not err to the extent that it concluded that the defense of voluntariness did not apply to the facts of the matter before it. During trial, Defendant argued that his conduct was directed by “command hallucinations,” and therefore, the involuntary conduct defense applied in this case. View "State v. Griffin" on Justia Law

In this defamation case, the Supreme Judicial Court affirmed the superior court’s dismissal of Marie Gunning’s complaint without prejudice for failure to effect service on the defendants, holding that Gunning was estopped from a prior California judgment from continuing to seek the Does’ identities. Marie Gunning brought suit against the anonymous publisher and writer (collectively, John Doe) of News as Viewed from a Crow’s Nest (Crow's Nest), a publication distributed locally in Freeport, Maine and accessible on the Internet, claiming that Crow’s Nest published defamatory statements about her in several of its issues. During the proceedings, a California court quashed a subpoena that Gunning served on the Crow’s Nest website host seeking to identify Doe. Thereafter, the superior court dismissed Gunning’s complaint without prejudice for failure to effect service on the defendants. The Supreme Judicial Court affirmed, holding that because the issue decided by the California court in a final judgment was the same issue that Gunning sought to have a Maine court revisit, and because Gunning had the opportunity and incentive to litigate that issue in California, she was estopped from relitigating it in the Maine action. View "Gunning v. Doe" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2), holding that the evidence was sufficient to support the judgment. Specifically, the district court did not err in finding, by clear and convincing evidence, at least one ground of parental unfitness and that termination of parental rights was in the best interest of the child. The child, now almost three and a half years old, was born drug affected. Mother was addicted to prescription drugs and failed to make significant progress in reunifying with the child over the past two years. View "In re River B." on Justia Law

Defendant appealed his conviction of operating under the influence (OUI) with a refusal to submit to a chemical test and of operating after suspension (OAS), arguing (1) the State failed to lay a proper foundation for the admission of testimony regarding horizontal gaze nystagmus (HGN) tests performed on Defendant after he was stopped for a traffic violation; and (2) the court committed obvious error by considering testimony from the OUI portion of the trial - as presented to the jury - to conclude that the State proved the operation element of the OAS charge - which was decided by the court. The Supreme Judicial Court affirmed, holding (1) the State laid a proper foundation for the admission of testimony regarding the HGN tests pursuant to State v. Taylor; and (2) where the trial court did not formally sever the OAS and OUI charges and, rather, the parties agreed before trial to have the court decide the OAS charge for “strategic reasons,” the court did not commit obvious error when it considered testimony presented to the jury on the OUI charge in deciding the OAS charge. View "State v. Hinkel" on Justia Law