Justia Maine Supreme Court Opinion Summaries

Elizabeth Jalbert, a teacher, filed an application for disability retirement benefits with the Maine Public Employees Retirement System (MPERS) after she twice fell and slipped on ice, hitting her head each time. An Executive Director’s designee ultimately denied Jalbert’s application. Jalbert appealed to the MPERS Board of Trustees. The hearing officer issued a recommended final decision concluding that Jalbert had not satisfied her burden of proving that her conditions made it impossible to perform the duties of her employment position. The Board adopted the hearing officer’s decision in full. The superior court affirmed. The Supreme Judicial Court affirmed, holding that the record, when considered as a whole, did not compel the determination that Jalbert was disabled within the meaning of Me. Rev. Stat. 5, 17921(1), and therefore, the Board did not err in denying Jalbert’s application for disability retirement benefits. View "Jalbert v. Maine Public Employees Retirement System" on Justia Law

Green Tree Servicing, LLC filed a complaint against Thelma Cope to foreclose on her residential property. Green Tree later moved to dismiss its foreclosure complaint without prejudice on the grounds that it lacked standing to proceed with the action. The superior court denied Green Tree’s motion to dismiss the complaint without prejudice and instead dismissed the complaint with prejudice as a sanction for Green Tree’s pretrial conduct. Upon reconsideration, the court concluded that it did not have the authority to impose a dismissal with prejudice because Green Tree did not have standing to bring the foreclosure complaint in the first place. The court then entered an amended order that dismissed the action without prejudice. The Supreme Judicial Court vacated the judgment, holding that a trial court has the discretion to dismiss a foreclosure complaint with prejudice as a sanction even when the plaintiff lacks standing. Remanded. View "Green Tree Servicing, LLC v. Cope" on Justia Law

John F. Murphy Homes, Inc. operates a private school that offers medical services that are paid for by MaineCare, a State Medicaid program. The State pays one-third of costs for MaineCare, a contribution commonly referred to as the Seed. In 2013, Murphy Homes filed a complaint that, as construed by the trial court, stated claims for breach of contract, quantum meruit, and an equitable claim for unjust enrichment or equitable estoppel, alleging that it was owed $7.5 million for Seed payments not paid between 2001 and 2011. The trial court granted summary judgment for the State on all claims. The Supreme Judicial Court affirmed, holding (1) the breach of contract and quantum meruit claims were not legally viable; and (2) Murphy Homes failed to allege facts to generate a trial worthy issue of fact on the reliance element of its equitable estoppel claim. View "John F. Murphy Homes, Inc. v. State" on Justia Law

Mother’s two children were removed from Mother’s care because of her substance abuse and consequent neglect. More than two and a half years later, the district court terminated Mother’s parental rights to her children. Mother appealed. The Supreme Judicial Court affirmed, holding (1) contrary to Mother’s assertion, the district court’s judgment was the product of the proper exercise of its judicial function and was not defective; (2) the district court mistakenly relied on the reports of a guardian ad litem, but the error was harmless; and (3) the evidence was sufficient to support the termination of Mother’s parental rights. View "In re Caleb M." on Justia Law

After a jury trial, Defendant was convicted of one count of murder and one count of arson. The jury also found Defendant’s co-defendant guilty of three counts of murder and one count of arson. The Supreme Judicial Court affirmed, holding that the trial court (1) did not err when it instructed the jury on the defense of duress for the arson charge only and not for the murder counts; (2) did not abuse its discretion in denying Defendant’s motion for relief from prejudicial joinder with his co-defendant; (3) did not abuse its discretion when it permitted a witness to testify about guns she observed in a motel room during a meeting with Defendant and his co-defendant; (4) did not err when it denied Defendant’s motion to suppress cell phone records used to locate Defendant; and (5) did not err when it allowed testimony that insinuated Defendant “harmed people over drug debts.” View "State v. Sexton" on Justia Law

Amy Canney’s minor child, Nicholai, was bitten by a dog kept by Eric Burns, a neighbor who performed on-call maintenance work on properties owned by Strathglass Holdings, Inc. Canney filed a complaint on behalf of Nicholai against Strathglass, claiming that Burns was at all pertinent times the agent, servant or employee of Strathglass and was maintaining the property for the benefit of Strathglass. The superior court granted summary judgment for Strathglass, concluding that Burns was not acting within the scope of his employment at the time of the dog bite. The Supreme Judicial Court affirmed, holding (1) neither Burns’s acts or omissions nor Nicholai’s presence on his premises were related to Burns’s employment or agency with Strathglass, and therefore, summary judgment on Canney’s respondent superior claims was proper; and (2) Canney’s complaint failed to allege a theory of direct liability against Strathglass, and she offered no evidence that would support a direct claim of negligence against Strathglass. View "Canney v. Strathglass Holdings, LLC" on Justia Law

After a jury-waived trial, Defendant was convicted of manslaughter. The court sentenced Defendant to twelve years in prison. Defendant appealed, arguing that there was insufficient evidence to establish that his actions were voluntary and met the statutory definition of criminal negligence. The Supreme Judicial Court affirmed the judgment, holding (1) the court’s express finding that Defendant acted in a way that meets the definition of culpable negligence was supported by competent evidence in the record; and (2) the trial court found all the facts necessary to support its judgment given that those inferred findings were supported by evidence in the record. View "State v. Brown" on Justia Law

Edward Harshman instituted divorce proceedings against Sheila Harshman. Sheila counterclaimed for divorce. The court (1) adopted the parties’ agreement as to parental rights and contact, therefore awarding Sheila sole parental rights to the parties’ children; (2) divided the parties’ assets and debts; and (3) calculated Edward’s child support and spousal support obligations. Edward appealed from the divorce judgment, challenging the court’s exclusion of certain evidence at trial and the court’s calculation of the parties’ respective incomes for child support and spousal support purposes. The Supreme Judicial Court affirmed, holding that there was no abuse of discretion in the court’s exclusion of the evidence and in calculating each spouses’ income. View "Harshman v. Harshman" on Justia Law

After a jury trial, Defendant was convicted of fourteen criminal offenses, including four counts of aggravated attempted murder. The trial court imposed multiple life sentences in addition to multiple lesser sentences, all to be served concurrently. The Supreme Judicial Court affirmed the convictions and sentences. Defendant filed a petition for post-conviction review, asserting several grounds for relief, including ineffective assistance of appellate counsel. The court denied the petition, concluding that no error by appellate counsel was sufficiently prejudicial to justify any relief. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to relief under Strickland v. Washington. View "Fortune v. State" on Justia Law

Mother and Father, who were never married, were the parents of two minor children. Mother filed a complaint seeking a determination of parental rights and responsibilities. The court ultimately awarded sole parental rights and responsibilities and primary residence to Mother with rights of contact to Father. The Supreme Judicial Court affirmed, holding (1) the court did not commit clear error in its factual findings or abuse its discretion in its ultimate conclusion; and (2) the court did not abuse its discretion by requiring Father to participate in a psychological examination before having any contact with his children. View "Vibert v. Dimoulas" on Justia Law