Justia Maine Supreme Court Opinion Summaries

Defendant entered conditional guilty pleas to three drug-related crimes. Defendant appealed, arguing (1) the information contained in the warrant application to search his home was insufficient to allow a probable cause determination; (2) the court erred in allowing only the State to present evidence at a preliminary hearing that the court considered when denying Defendant’s motion for a Franks hearing; and (3) he made a substantial preliminary showing that entitled him to a Franks hearing. The Supreme Court vacated the judgment, holding (1) the trial court correctly denied that part of Defendant’s motion to suppress challenging probable cause; but (2) the hearing conducted by the trial court must be treated as the beginning of a Franks hearing, and therefore, the court erred by holding a hearing that did not allow Defendant to attempt to meet the burden of production necessary for a full Franks hearing. Remanded for the court to hold a full Franks hearing. View "State v. Thompson" on Justia Law

In 2012, the probate court appointed Aunt as the guardian of Child and awarded Grandmother rights of contact with Child. In 2015 and 2016, Aunt and Grandmother filed motions relating to the terms of the guardianships and Grandmother’s contact rights. The probate court denied the motions after a hearing. Further, upon Grandmother’s motion, the court found Aunt’s attorney (Attorney) in contempt and imposed sanctions against her. Both Aunt and Attorney appealed. The Supreme Judicial Court (1) affirmed the order denying Aunt’s motion, holding that there was no error in the court’s factual determinations; but (2) vacated the contempt finding and order of sanctions against Attorney, holding that Grandmother’s motion did not satisfy the procedural requirements of Me. R. Civ. P. 66(d)(2)(C), and the court did not implement the process required by that rule. View "Guardianship of Isabella Ard" on Justia Law

Attorney Susan Thiem represented Ann Thomas, an allegedly incapacitated person, during this action for appointment of a guardian and conservator. During the proceedings, the probate court issued an order imposing sanctions against Thiem based on a finding that she had “unreasonably interfered” with the discovery process. The sanctions order required Thiem to pay reasonable expenses, including attorney fees. Thiem appealed, arguing that the court abused its discretion by imposing sanctions. The Supreme Judicial Court dismissed the appeal as interlocutory without reaching the merits, holding that because the court had not yet quantified the amount of any attorney fees and expenses to be paid by Thiem as a sanction, the sanctions order was not a final judgment suitable for appellate review. View "Conservatorship & Guardianship of Ann B. Thomas" on Justia Law

Defendant pleaded guilty to one count of robbery. Defendant later admitted to four violations of his probation. The court enrolled Defendant in drug court. After he entered the program, Defendant again violated the conditions of his probation. Following a hearing to determine whether to expel Defendant from the drug court program, the court revoked Defendant’s probation and imposed a sentence of five years. Defendant filed a petition for post-conviction review, arguing that his due process and equal protection rights had been violated at the drug court termination hearing. The State moved to dismiss Defendant’s petition based on a lack of subject matter jurisdiction, arguing that Me. Rev. Stat. 15, 2121, 2124 expressly barred post-conviction review of a probation revocation. The court denied the State’s motion to dismiss and granted Defendant’s petition for post-conviction review. The Supreme Court vacated the judgment and remanded with instructions to dismiss the petition for post-conviction review, holding (1) in this case, the proper path to obtain review is to file a notice of appeal; and (2) the court did not abuse its discretion in expelling Defendant from drug court and revoking his probation. View "Spinney v. State" on Justia Law

After a jury trial, Defendant was convicted of baiting deer and hunting from an observation stand overlooking deer bait. The Supreme Court affirmed, holding (1) the instructions given by the trial court fairly and accurately informed the jury of all necessary elements of the governing law, and therefore, Defendant was not deprived of a fair trial; and (2) statements by the prosecutor during his opening and closing that purported to explain that hunting regulations and statutes were premised on a need to keep a level playing field among hunters were improper, but the error was not plain, nor did the error affect Defendant’s substantial rights or the outcome of the trial. View "State v. Lajoie" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence with one prior conviction. Defendant appealed, arguing that the trial court abused its discretion by excluding testimony that certain chemicals could have resulted in a falsely elevated breath-alcohol test if they were present in Defendant’s system when he took the breath test. The Supreme Court affirmed, holding that, under the particular factual circumstances of this case, the trial court did not abuse its discretion by excluding the testimony about the effect of those chemicals on breath-testing equipment and test results produced by that equipment because there was not a sufficient factual foundation to link the testimony with the facts of this case. View "State v. Rourke" on Justia Law

Petitioner filed a petition in the superior court challenging a disciplinary decision by the Department of Corrections. The superior court dismissed the petition, concluding that Petitioner failed to state a claim where the court could not “determine its jurisdiction in the absence of its determination of the date of the final agency action.” Petitioner later filed a motion pursuant to Me. R. Civ. P. 60(b) to set aside the order dismissing his petition. The superior court denied the Rule 60(b) motion. The Supreme Judicial Court vacated the judgment, holding that the superior court erred in dismissing the petition for lack of jurisdiction because the court improperly required that the petition include content not statutorily required and presumed a lack of jurisdiction without a basis to do so. Remanded. View "Mutty v. Department of Corrections" on Justia Law

After a public hearing, the Town of Stockton Spring’s Board of Selectman determined that a structure owned by Hollie Beal was a dangerous building or nuisance pursuant to Me. Rev. Stat. 17, 2851. The superior court affirmed the decision of the Board. The Supreme Judicial Court affirmed, holding (1) Beal’s contention that the Board violated her due process rights when it allegedly denied her the opportunity to be heard, to cross-examine witnesses, and to have an impartial fact-finder was unavailing; and (2) there was substantial evidence in the record to support the Board’s findings. View "Beal v. Town of Stockton Springs" on Justia Law

Steven L., who suffered from a severe and persistent mental illness, was twice involuntarily admitted to a progressive treatment program for a period of one year. In 2015, a psychiatric hospital operated by the Department of Health and Human Services applied to the district court for a twelve-month extension of the progressive treatment program order. The district court granted the motion and ordered the extension. The superior court affirmed. Steven then appealed to the Supreme Judicial Court. The Court affirmed, holding that the trial record supported the court’s findings by clear and convincing evidence. View "In re Steven L." on Justia Law

Defendant entered a conditional guilty plea to a charge of unlawful possession of schedule W drugs, preserving his right to appeal from the denial of his motion to suppress. Defendant appealed, arguing that the trial court erred by denying his motion to suppress evidence of drugs that he was carrying in a body cavity because law enforcement officers exceeded the authority granted them by two search warrants explicitly authorizing a search of Defendant’s person. The Supreme Court affirmed, holding that, under the facts of this case, the trial court did not err in denying the motion to suppress. View "State v. Cooper" on Justia Law