Justia Maine Supreme Court Opinion Summaries

After a nonjury trial, Defendant conceded that he had committed the offense of operating a vehicle with an expired registration. The trial court trial court adjudicated Defendant to have committed the traffic infraction of failing to register his vehicle for a period of between thirty and 150 days after his previous registration had expired. The Supreme Judicial Court affirmed, holding (1) the trial court did not err by denying Defendant’s request for a jury trial; and (2) there was no error in the trial court’s handling of Defendant’s various requests for accommodation for his claimed disabilities. View "State v. Chase" on Justia Law

David Bordetsky filed a complaint for foreclosure against JAK Realty Trust, alleging that Gregory O’Halloran, as trustee of the Trust, executed a promissory note secured by a mortgage on property located in Benton and that the Trust had defaulted on the note. After a nonjury trial, the court issued a judgment in favor of the Trust, concluding that Bordetsky was required to, but did not, comply with the requirements for a notice of default and right to cure contained in Me. Rev. Stat. 14, 6111. The Supreme Judicial Court vacated the judgment, holding that the requirements for a notice of default and right to cure contained in section 6111 did not apply to Bordetsky’s foreclosure action against the Trust. Remanded. View "Bordetsky v. JAK Realty Trust" on Justia Law

Plaintiffs were employed by Shaw’s Supermarkets, Inc. when their employment was terminated as part of a reduction in force. The reduction in force affected more older employees than younger employees. Plaintiffs filed complaints with the Maine Human Rights Commission alleging age discrimination in violation of the Maine Human Rights Act (MHRA). A Commission investor applied the “business necessity” framework to analyze Plaintiffs’ allegations before recommending that the Commission find reasonable grounds to believe that Shaw’s had impermissibly discriminated based on age pursuant to a disparate impact theory. The Commission voted unanimously to adopt the investigator’s analysis and recommendations. Plaintiffs then filed a complaint alleging unlawful employment discrimination based on age pursuant to the MHRA. The federal district court certified to the Supreme Court the question of what framework of proof applies to a claim of disparate impact age discrimination brought pursuant to the MHRA. The Supreme Court answered that a claim for disparate impact age discrimination pursuant to the MHRA is evaluated according to the “business necessity” standard, rather than the “reasonable factor other than age” standard or some other standard. View "Scamman v. Shaw's Supermarkets, Inc." on Justia Law

Appellant was convicted of murdering a sixteen-year-old girl. The Supreme Judicial Court affirmed. This appeal concerned Appellant’s second petition for postconviction review, which asserted sixteen grounds. The first five grounds asserted that the attorney who represented Appellant in his first petition for postconviction review was ineffective in several respects. The trial court dismissed those grounds, concluding (1) Maine law does not permit a second petition to challenge the effectiveness of counsel who represented a petition in a prior petition; and (2) the United States Supreme Court’s decision in Martinez v. Ryan was not retroactive and, therefore, had no effect on Appellant’s first petition, which was denied before Martinez was decided. The court then denied the remainder of Appellant’s petition after an evidentiary hearing. The Supreme Judicial Court affirmed, holding that Martinez did not provide Appellant with the right to challenge the effectiveness of postconviction counsel in a subsequent postconviction review petition. View "Reese v. State" on Justia Law

Wife filed for divorce from Husband after six years of marriage on the ground of irreconcilable differences. The district court entered a divorce judgment dividing the parties’ property, awarding child support to Wife, denying spousal support in favor of Wife, and denying Wife’s request for attorney fees. Wife filed several post-judgment motions, without success. On appeal, Wife took a “buckshot approach,” arguing numerous substantive and procedural issues in the apparent effort that “something will stick.” The Supreme Judicial Court affirmed, holding that any potentially meritorious points on appeal, if any exist, have been listed in the fog of insubstantial and unsupportable objections to the trial process and the trial court’s decision. View "Millay v. McKay" on Justia Law

Husband initiated divorce proceedings from Wife in Sweden. Wife objected to the proceedings, asserting that the Swedish court did not have personal jurisdiction over her. The Swedish court subsequently stayed the action for a six-month “reconsideration period.” While the Swedish action was in the reconsideration period, Wife initiated a divorce action in Maine. Husband moved to dismiss the complaint for forum non conveniens. The district court denied Husband’s motion. Thereafter, the Swedish court entered a divorce judgment dissolving the parties’ marriage. The Maine court then dismissed Wife’s complaint on the grounds that the Swedish judgment was a complete bar to Wife’s divorce action. The Supreme Judicial Court (1) affirmed the Maine court’s judgment to the extent it dismissed the portion of Wife’s complaint seeking dissolution of her marriage; but (2) vacated the judgment insofar as it dismissed Wife’s remaining claims for spousal support, division of marital property, and reasonable attorney fees, holding that it was premature for the district court to address these issues where the Swedish court had yet to address them. View "Lynch v. Lynch" on Justia Law

Mother appealed from the district court’s judgment terminating her parental rights to her daughter. The Supreme Judicial Court affirmed, holding (1) the district court’s findings that Mother was unable to protect her daughter from jeopardy or take responsibility for the child in a reasonable time were sufficient to allow for appellate review; (2) the evidence was sufficient to support the court’s determination that Mother was unable to take responsibility for her daughter and would not be able to do so in a reasonable time; (3) the court did not err by finding by clear and convincing evidence that Mother was unable to protect her daughter from jeopardy and would not be able to do so in a reasonable time; and (4) there was no error or abuse of discretion in the court’s finding that termination was in the child’s best interest. View "In re Aubrey R." on Justia Law

Defendant was charged by complaint with operating under the influence based in part on an allegation of a blood test measuring 0.15 grams of alcohol per 100 milliliters of blood. Defendant moved to suppress the evidence obtained through the blood test. The trial court granted the motion to suppress, finding that the police officer did not obtain a warrant or seek Defendant’s consent, that Defendant did not consent to the blood test, and that there were no exigent circumstances generating an exception to the warrant requirement. The State appealed. The Supreme Judicial Court affirmed, holding that the record did not compel a finding that Defendant objectively manifested consent to the drawing and testing of his blood through his mere acquiescence and cooperation. View "State v. Boyd" on Justia Law

After William Dean was involuntarily hospitalized, the Department of Health and Human Services was appointed as Dean’s temporary public conservator. Thereafter, the Department sold some of Dean’s property. Dean’s sister, Claire Perry, filed a complaint against the Department and certain state individuals, asserting claims arising out of the Department’s management of Dean’s property during the public conservatorship. Later, Pamela Vose was appointed as Dean’s conservator. Vose filed a cross-claim and then a separate action against the Department, alleging breach of fiduciary duty. The court consolidated the two cases. The Department and the individual state defendants moved for summary judgment, asserting sovereign immunity. The court entered a summary judgment in favor of the defendants on most claims but denied the Department’s motions for summary judgment on Vose’s claim for breach of fiduciary duty in both cases, concluding that the Maine Probate Court waived sovereign immunity and that the Department was subject to suit in tort when acting as a public conservator. The Supreme Judicial Court vacated the order denying the Department’s motions for summary judgment, holding that the Department is immune from the breach of fiduciary duty claims asserted in these cases because the Probate Code does not expressly waive sovereign immunity and the Department did not waive immunity. View "Perry v. Dean" on Justia Law

In 2015, the three children of Mother and Father came into the custody of the Department of Health and Human Services. After the Department’s efforts to reunify the family failed due to a combination of the parents’ mental health issues and their choices, the trial court terminated Mother’s and Father’s parental rights to their children. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence to support the court’s findings that the parents were unwilling or unable to protect the children from jeopardy and that these circumstances were unlikely to change within a time reasonably calculated to meet the children’s needs; and (2) there was sufficient evidence to support the court’s finding that termination was in the best interest of the children. View "In re Gracesun C." on Justia Law