Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and theft by deception. Defendant appealed, arguing (1) the evidence presented at trial was insufficient to support the convictions, and (2) the trial court violated her right to be free from double jeopardy by convicting and sentencing her on both counts of theft without consolidating them. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support both convictions; and (2) the trial court did not err by entering a judgment of conviction on each count of theft or by sentencing Defendant on both counts of theft, and furthermore, there was no violation of Defendant’s right to be free from double jeopardy because the convictions and sentences were not based on a single criminal act. View "State v. Hayward" on Justia Law

JPMorgan Chase Bank, N.A. filed a complaint against Terrance Lowell seeking foreclosure on residential property. The complaint alleged that Lowell had defaulted by failing to make payments due on a promissory note. After a bench trial, the district court entered a judgment of foreclosure in favor of JPMorgan. The Supreme Judicial Court vacated the judgment, holding (1) the district court properly admitted certain documents pursuant to the business records exception to the hearsay rule; but (2) the district court erred by finding that the notice of default issued by JPMorgan complied with the requirement established in Me. Rev. Stat. 14, 6111(1-A)(C), which is a required element of foreclosure. Remanded for entry of judgment in favor of Lowell. View "JPMorgan Chase Bank, N.A. v. Lowell" on Justia Law

In 2011, the York County Probate Court appointed Daniel Golodner’s stepmother, Gail Golodner, as the full, permanent guardian of Daniel’s minor daughter, Alisha Golodner. In 2014, Daniel filed a petition to terminate the guardianship. The probate court denied Daniel’s petition after a hearing. Daniel appealed. Thereafter, Gail died. Daniel filed a motion for relief from the probate court’s order asking the Supreme Court to “clarify and settle his status as sole custodian.” The Supreme Court vacated and remanded the portion of the judgment relating to the court’s order regarding guardian ad litem fees as a sanction, and dismissed the appeal in all other respects, as it presented issues that have become moot. The Court further ordered the immediate return of the case file to the probate court with the directive that it take action regarding Alisha’s care. View "In re Guardianship of Alisha K. Golodner" on Justia Law

Defendant pleaded unconditionally guilty to a charge of receiving stolen property. The trial court accepted the open plea, which Defendant never moved to withdraw. Defendant appealed. The State moved to dismiss the appeal on the ground that Defendant cannot take a direct appeal from his plea of guilty absent a challenge to the trial court’s jurisdiction or the constitutionality of his punishment. The Supreme Court granted the motion and dismissed the appeal because Defendant pleaded guilty unconditionally, did not move to withdraw his plea, and did not contend that the trial court lacked jurisdiction or that it imposed an unconstitutional sentence. View "State v. Stevens" on Justia Law

After a hearing, the State Board of Nursing found that John S. Zablotny had violated his professional duties and revoked his nursing license for two years. The district court affirmed. The Supreme Court vacated the judgment and remanded for further proceedings, concluding that the district court erred in conducting an appellate-type review. On remand, the district court concluded that Zablotny had engaged in activities that constituted professional misconduct but also concluded that the Board failed to prove other allegations of professional misconduct. The Supreme Judicial Court affirmed, holding that the district court’s findings supported the conclusion that the court was not compelled, as a matter of law, to find that Zablotny violated Board rules or professional standards of care. View "Zablotny v. State Board of Nursing" on Justia Law

Defendant pleaded guilty to three counts of gross sexual assault and two counts of unlawful sexual contact. The court sentenced Defendant to twenty years’ imprisonment followed by fifteen years of supervised release. Defendant challenged his sentence on appeal, arguing, inter alia, that the supervised release sentencing process, mandated by law, violates the due process clause and the double jeopardy clause. The Supreme Judicial Court affirmed, holding (1) Defendant’s due process argument actually addresses the length of his total sentence, and the sentence is not constitutionally disproportionate or cruel or unusual punishment; (2) the supervised release sentencing process does not violate the Double Jeopardy Clause; and (3) the supervised release statutory scheme does not abrogate the traditional Hewey analysis. View "State v. Parker" on Justia Law

The district court entered judgment terminating Father’s parental rights to his child. The Supreme Judicial Court affirmed, holding (1) the Court need not reach Father’s argument that the district court violated his due process right by applying a rebuttable presumption of parental unfitness and improperly placing the burden of proof on him because the court also found an alternative form of parental unfitness; (2) the court’s affirmative findings supporting its parental unfitness determination were supported by the evidence; and (3) the district court did not err or abuse its discretion in finding that termination was in the child’s best interest. View "In re Forest G." on Justia Law

Defendant pleaded guilty of burglary and theft by unauthorized taking or transfer. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements made during a police interview while he was detained in county jail awaiting a court appearance for a probation violation on an unrelated charge because he was not provided with Miranda warnings prior to a custodial interview. The Supreme Judicial Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress because Defendant was not in custody within the meaning of Miranda when he was interviewed by detectives. View "State v. Ames" on Justia Law

After a jury trial, Defendant was convicted of one count of arson. The conviction stemmed from a fire that largely destroyed a diner run by Defendant. Defendant appealed, arguing, inter alia, that the trial court erred by admitting expert testimony concerning the cause of the fire. The Supreme Judicial Court affirmed, holding (1) the trial court did not clearly err by admitting the expert opinion testimony concerning the cause of the fire; (2) the trial court did not abuse its discretion by allowing Defendant’s acquaintance to testify about statements he made to Defendant about how to start house fires; and (3) the evidence was sufficient to establish that Defendant intentionally set the fire. View "State v. Maine" on Justia Law

Midland Funding LLC filed suit against Mark Walton alleging that he had entered into a credit card agreement with Barclays Bank Delaware, used the card to obtain extensions of credit, and failed to make payments on the account. Midland purchases debt from Barclays. Midland sought to collect an outstanding balance of $5,684.72. After a trial, the district court entered judgment in favor of Midland in the amount of $5,684.72, plus costs. The Supreme Judicial Court affirmed the judgment, holding (1) jurisdiction over this matter was properly established in the district court; and (2) the district court did not err in admitting documentation of the assignment of Walton’s debt from Barclays to Midland pursuant to the business record exception to the hearsay rule. View "Midland Funding LLC v. Walton" on Justia Law