Justia Maine Supreme Court Opinion Summaries

In this case, Randall C. Belyea was the sole shareholder and president of Belyea Enterprises, Inc. (BEI), which had a contract with FedEx. Due to a misdemeanor charge, FedEx refused to renew the contract with Belyea, leading him to transfer his interest in BEI to his fiancée, Heather A. Campbell, under the understanding that she would be the owner in name only while he continued to run the business. However, in 2018, Campbell terminated Belyea's employment and restricted his access to BEI's bank accounts.The Superior Court (Aroostook County) initially granted Campbell’s motion for judgment as a matter of law on Belyea’s conversion claim and later entered judgment as a matter of law in favor of Campbell on Belyea’s breach of contract claim, despite a jury verdict in Belyea’s favor. The court found that there was insufficient evidence of an enforceable contract between Belyea and Campbell, as the terms were too vague and indefinite.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's decisions. The court held that the terms of the alleged contract between Belyea and Campbell were not sufficiently definite to form an enforceable contract. The terms did not clearly define the roles and obligations of each party, the duration of the contract, or the details regarding a possible reconveyance of BEI to Belyea. Consequently, the court also upheld the judgment in favor of Campbell on the conversion claim, as Belyea did not have a legal interest in BEI in 2018. View "Belyea v. Campbell" on Justia Law

A group of plaintiffs, including William Clardy, Michelle Tucker, two state representatives, and a nonprofit corporation, filed a lawsuit against Maine's Senate President, Speaker of the House, and Governor. They sought to invalidate a special legislative session called by the Governor, arguing it was unconstitutional. The plaintiffs claimed the session was based on a "contrived" extraordinary occasion and that the legislative leaders ceded power to the executive branch. They sought declarations that the session and the legislation passed during it were void.The Kennebec County Superior Court dismissed the complaint for failure to state a claim. The court did not decide on the plaintiffs' standing but ruled that the Governor's determination of an extraordinary occasion to convene the Legislature was not subject to judicial review. Additionally, the court found that the legislative leaders were immune from suit for their actions. The plaintiffs appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the dismissal, but on different grounds. The court held that the plaintiffs lacked standing to bring the suit. The court found that the individual plaintiffs, as citizens and taxpayers, did not demonstrate a particularized injury distinct from the general public. The state representatives failed to show a concrete injury arising from the Governor's proclamation or the convening of the special session. Lastly, the nonprofit corporation lacked standing because its members did not have standing to sue individually. The court concluded that no plaintiff had suffered an injury sufficient to confer standing, thus affirming the lower court's dismissal of the case. View "Clardy v. Jackson" on Justia Law

The Industrial Energy Consumer Group (IECG) appealed an order from the Public Utilities Commission (PUC) regarding the recovery of costs related to power supply obligations and state energy programs. The PUC decided that these costs should be recovered volumetrically from all ratepayer classes, except for one category, which should be recovered using a fixed customer charge. IECG argued that the order was preempted by the Federal Power Act and that the allocation and design violated cost-causation principles and state statutes.The Office of the Public Advocate contended that IECG’s appeal was untimely and should be dismissed. The PUC argued that the appeal was an improper collateral attack on a prior rate order. Both the Public Advocate and the PUC maintained that if the merits were considered, the order should be affirmed as rational and supported.The Maine Supreme Judicial Court concluded that the appeal was timely and not barred by collateral estoppel. The court did not address the preemption argument, finding it unpreserved for appellate review. The court rejected IECG’s arguments on the merits, noting the deferential standard of review for the PUC’s expert judgment in ratemaking. The court found that the PUC’s decision to treat NEB costs separately from traditional T&D service costs was rational and supported by the record. The court also determined that the PUC’s allocation and rate design did not violate state statutes.The court affirmed the PUC’s order, holding that the PUC’s approach to NEB cost recovery was within its broad discretion and sufficiently justified. The court noted that the PUC might refine its approach in the future based on further data collection and party input. View "Industrial Energy Consumer Group v. Public Utilities Commission" on Justia Law

Patrick Gordon, an attorney, was suspended from the rosters of the Maine Commission on Public Defense Services, making him ineligible to represent indigent criminal defendants. The suspension followed an investigation into Gordon’s billing practices and representation of a client. The Commission received information suggesting that Gordon had inaccurately billed for a jury trial that was actually a bench trial and that some billed work was performed by others in his firm. Additionally, there were discrepancies regarding Gordon’s client visits.The Superior Court (Kennebec County) affirmed the Commission’s decision. The investigation began after the Commission received information from a post-conviction review counsel. Gordon was asked to provide documents and clarify billing discrepancies but failed to fully comply. Despite multiple requests and extensions, Gordon did not provide the requested documents or satisfactory explanations. The Commission’s Interim Executive Director, Justin Andrus, ultimately suspended Gordon, a decision upheld by the Commission after an intra-agency appeal.The Maine Supreme Judicial Court reviewed the case and affirmed the Superior Court’s judgment. The Court found that the Commission’s decision was not arbitrary or capricious. The evidence showed that Gordon failed to comply with the Commission’s requests, which were within the Commission’s authority. The investigation and subsequent suspension were justified based on Gordon’s non-compliance with the Commission’s rules. The Court concluded that the Commission’s decision was supported by evidence and did not reflect any abuse of discretion or erroneous findings of fact. View "Gordon v. Maine Commission on Public Defense Services" on Justia Law

The case involves a divorce judgment from the District Court in Biddeford, where the court disposed of the marital property and awarded Cynthia (Pray) Wood McKenna $8,400 per month in general spousal support for life. Thomas Pray appealed, arguing that the court double-counted the value of trucks used in his pest-control business, failed to account for the value of the business attributable to his personal goodwill, engaged in improper "double dipping" by relying on his income from the business to determine both the value of the business and the amount of spousal support, failed to consider all relevant spousal support factors, and abused its discretion in awarding attorney fees to Wood McKenna.The District Court awarded Wood McKenna the marital residence, several IRAs, bank accounts, and personal property, while Pray received an IRA, credit union accounts, the pest-control business, and trucks. To equalize the property division, Pray was ordered to pay Wood McKenna $288,150. The court also awarded Wood McKenna spousal support based on several statutory factors, including the length of the marriage, disparity in earnings, age difference, and her health condition. Pray filed a motion for further findings of fact and conclusions of law, which the court denied without altering its findings.The Maine Supreme Judicial Court reviewed the case and found that the District Court erred in double-counting the trucks' value in the property allocation and in making insufficient findings to explain the spousal support award. The court vacated the property disposition and spousal support award and remanded for further consideration. The court dismissed Pray's appeal regarding attorney fees as not ripe for review. The court held that the lower court must reconsider its calculations and any effect on the division of marital property, and make specific findings regarding Pray's income and the income potential from the assets awarded to Wood McKenna. View "McKenna v. Pray" on Justia Law

The Connary heirs appealed a summary judgment favoring the Shea brothers regarding the reformation of the Shea Family Living Trust. The Trust, established by William and Patricia Shea, included a provision to distribute bank stock to the Connary heirs. However, the bank recalled and redeemed the stock, and the Trust received approximately $460,000. After Patricia's death, the successor trustee determined the stock was no longer part of the Trust and refused to distribute money in lieu of the stock to the Connary heirs.Initially, the Superior Court (Stewart, J.) ruled that the Trust's legacy of the bank stock was a specific devise that had adeemed, meaning the stock was no longer part of the Trust. The court dismissed Connary's reformation claim without specific litigation on that issue. On appeal, the Maine Supreme Judicial Court affirmed the interpretation of the Trust but remanded the case for further proceedings on the reformation claim.On remand, the Superior Court (O’Neil, J.) granted summary judgment to the Shea brothers, concluding that Connary had not provided admissible evidence to generate a genuine dispute of fact regarding the reformation claim. Connary argued that Patricia's statements to family members about her intent should be considered, but the court ruled this evidence inadmissible.The Maine Supreme Judicial Court reviewed the case and concluded that even if Patricia's statements were admissible, Connary's reformation claim could not survive summary judgment. The court held that reformation is only available to conform to both settlors' intentions if affected by a mistake. There was no evidence of William's intent or mistake regarding the bank stock. Additionally, reformation cannot be used to address changes in circumstances that occurred after the Trust's execution. Therefore, the judgment was affirmed. View "Connary v. Shea" on Justia Law

Michael T. Smith was convicted of twelve counts of unlawful sexual contact after a jury trial. The charges stemmed from allegations that Smith sexually abused his stepdaughter between 2011 and 2014 and his daughter between 2011 and 2019. The Oxford County Sheriff’s Office received a report in September 2019, leading to separate interviews of the victims. Smith’s stepdaughter disclosed abuse, resulting in an initial indictment. Later, Smith’s daughter also reported abuse, leading to a superseding indictment with additional charges.The trial court denied Smith’s motion for relief from prejudicial joinder, which sought to separate the charges involving his stepdaughter from those involving his daughter. The court found the charges were connected by time, purpose, and modus operandi, and that evidence of abuse of one victim would be admissible in a trial concerning the other. The court also allowed Kathy Harvey-Brown, a forensic interviewer with a background in social work, to testify as an expert on delayed disclosure of child sexual abuse, despite Smith’s objections regarding her qualifications.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decisions. The court held that the joinder of charges was proper and did not result in undue prejudice, as the evidence of abuse was interconnected and would be admissible in separate trials. The court also found that Harvey-Brown was qualified to testify based on her extensive training, experience, and familiarity with the relevant research. The court concluded that the trial court did not abuse its discretion in either denying the motion for relief from joinder or in allowing the expert testimony. View "State of Maine v. Smith" on Justia Law

Steven Edwards was convicted by a jury of eighteen counts of possession of sexually explicit material involving minors under 12 years old. The charges stemmed from images found on his computer during a search executed with a warrant. Edwards challenged the court's decisions on several motions, including a motion to suppress evidence, arguing the warrant was based on stale information, and motions for judgment of acquittal, mistrial, and a new trial.The Somerset County court denied Edwards's motion to suppress, finding that the information supporting the warrant was not stale. The court noted that the Maine State Police Computer Crimes Unit had received multiple tips from the National Center for Missing and Exploited Children about uploads from Edwards's IP address. The court also found that consumers of child pornography often retain such material for long periods, supporting the warrant's issuance.At trial, the court heard testimony from law enforcement and forensic experts. Edwards moved for a judgment of acquittal, arguing insufficient evidence that he possessed or accessed the images with intent to view them. The court denied the motion, and the jury found Edwards guilty on all counts. Edwards's post-trial motions for a mistrial and a new trial were also denied, despite his argument that the prosecutor's comments during closing arguments were prejudicial.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's decisions. The court held that the information supporting the search warrant was not stale and that there was sufficient evidence for the jury to find Edwards guilty. The court also found that the trial court's curative instruction was adequate to address any potential prejudice from the prosecutor's comments, and there was no abuse of discretion in denying the motions for a mistrial and a new trial. View "State of Maine v. Edwards" on Justia Law

Matthew A. Dennis was convicted of possession of a firearm by a prohibited person and violation of a condition of release following a jury-waived trial. The case arose when Officer Seth Burnes responded to a report of a disturbance at 68 Elm Street, where Dennis, who was under bail conditions to avoid contact with the victim, was found arguing with the victim. During the incident, Dennis was seen with a jacket containing a black-powder pistol, which appeared to have been fired. Dennis was arrested and charged accordingly.The trial court (Penobscot County, A. Murray, J.) denied Dennis's motion to suppress evidence and proceeded with a bench trial. During cross-examination, it was revealed that the pistol had been test-fired by police six days before the trial, and this information had been uploaded to the ShareFile platform used for discovery. Dennis's counsel argued that the late disclosure was unfair and requested dismissal or exclusion of the evidence. The court found no discovery violation but acknowledged the late disclosure and allowed Dennis to review the test-firing video and offered the opportunity to conduct his own test-firing, which Dennis declined.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that there was no discovery violation as the test result was provided within two days of its existence and before the trial. The court found that the trial court's remedy, which included allowing Dennis to review the test-firing video and offering the opportunity for his own test, was appropriate and did not deprive Dennis of a fair trial. The court concluded that the trial court's actions sufficiently mitigated any potential prejudicial effect of the late test-firing. View "State of Maine v. Dennis" on Justia Law

Pedro Rosario was convicted of aggravated trafficking of scheduled drugs in 2021 and sentenced to twenty-five years in prison, with ten years suspended, four years of probation, and a $25,000 fine. His conviction was affirmed by the Maine Supreme Judicial Court in 2022. In April 2023, Rosario filed a motion to vacate the judgment and for a new trial, alleging that a juror was improperly seated and biased. The State accepted the allegations as true for the purposes of the motion.The trial court held a non-testimonial hearing and found that during jury selection, Rosario’s counsel wanted to voir dire Juror 23, but another juror was brought forward by mistake. Juror 23 was selected as an alternate but was mistakenly seated as a juror when another juror was dismissed. Rosario’s attorney did not object at the time. Later, Rosario’s attorney discovered that Juror 23 had attended high school with the District Attorney but had not spoken to him since. The trial court determined that this information was not newly discovered evidence and denied Rosario’s motion for a new trial.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that Rosario’s motion was untimely under M.R.U. Crim. P. 33, as the information about Juror 23 was known before the trial concluded. The court also found no evidence of juror bias or misconduct that would warrant a new trial. The court concluded that Rosario received a fair trial by an impartial jury and upheld the trial court’s judgment. View "State of Maine v. Rosario" on Justia Law