Justia Maine Supreme Court Opinion Summaries

Defendant was convicted of domestic violence assault, domestic violence stalking, and endangering the welfare of a child. The Supreme Judicial Court vacated the judgment of conviction as to the charge of domestic violence assault and remanded for entry of a judgment of acquittal on that charge, holding that the record contained insufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant’s conduct forming that basis for domestic violence assault occurred within the relevant limitations period. The Court also remanded to determine whether resentencing was necessary as to the stalking and endangering the welfare of a child charges. View "State v. Lacourse" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated assault, two counts of domestic violence assault, and related offenses. Defendant appealed, arguing, inter alia, that the court erred in denying his motion to suppress statements he made to a police officer prior to his arrest. Defendant also appealed his sentence. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that Defendant was not in custody for Miranda purposes and consequently denying his motion to suppress; (2) the court did not abuse its discretion in admitting the testimony of an expert witness who testified about the causes, effects, and symptoms of strangulation; and (3) the court did not abuse its discretion in sentencing Defendant. View "State v. Perry" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder. The Supreme Judicial Court affirmed the judgment, holding (1) the motion court did not err in denying Defendant’s motion to suppress statements he made to law enforcement officers prior to 12:44 p.m. on July 18, 2013 because Defendant was not in custody for Miranda purposes that morning; (2) the motion court did not err in concluding that the Miranda violation occurring after 12:44 p.m. on July 18 did not mandate suppression of statements made on July 23 and 24; (3) the State’s attorney did not commit prosecutorial misconduct during opening statement and closing argument; and (4) the State presented sufficient evidence to support the murder conviction. View "State v. Cote" on Justia Law

After Henry B. was admitted to Pen Bay Medical Center (PBMC), PBMC staff applied to involuntarily commit Henry pursuant to the “white paper” procedures of Me. Rev. Stat. 34-B, 3863(5-A). After a commitment hearing, the district court ordered that Henry be submit to involuntary hospitalization for up to 120 days. The superior court affirmed the district court’s judgment of involuntary commitment. Henry appealed, arguing that he was not provided with effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) individuals subject to involuntary commitment proceedings in Maine have the right to effective representation of counsel, and the Strickland standard applies for courts reviewing claims of ineffective assistance of counsel in involuntary commitment proceedings; and (2) Henry was not deprived of the effective assistance of counsel in this case. View "In re Henry B." on Justia Law

After a jury trial, Defendant was found guilty of domestic violence assault and obstructing the report of a crime or injury. The court sentenced Defendant to three years’ incarceration with all but nine months suspended and three years’ probation, plus fees. The Supreme Judicial Court affirmed, holding (1) the trial court did not commit prejudicial error by not sua sponte declaring a mistrial when the prosecutor commented on Defendant’s right not to testify during the State’s rebuttal closing argument; and (2) the trial court did not err by denying Defendant’s motions for a mistrial after the jury heard statements by the victim regarding Defendant’s prior interactions with police and the victim’s consultation with a domestic violence program and acquisition of a protection order. View "State v. Tarbox" on Justia Law

In 2014, Joyce Mitchell filed a complaint for divorce from Alexander Krieckhaus. In 2016, the parties reached a settlement agreement. A stipulated order on children’s issues was signed by the court on that date. The court later entered a divorce judgment in which it based the amount of child support upon the parties providing substantially equal care for their son. Mitchell subsequently filed a motion for findings of fact and conclusions of law, reconsideration of the child support order, and deviation from the child support guidelines, arguing, inter alia, that before the court issued a child support order it was required to hold an evidentiary hearing on the issue of whether the parties provided substantially equal care of their son. The court issued an order denying all of Mitchell’s motions. The Supreme Court vacated the judgment of divorce insofar as it established a child support obligation to be paid by Mitchell and remanded for an evidentiary hearing on that issue, holding that the court erred in finding that the parties had agreed to a substantially equal care arrangement with regard to their son without providing the parties with a meaningful opportunity to present evidence on this issue. View "Mitchell v. Krieckhaus" on Justia Law

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