Justia Maine Supreme Court Opinion Summaries

The probate court issued an adjudication of incapacity and appointed the Department of Health and Human Services as the public guardian of Harold Sanders, finding that Sanders was incapacitated, that no suitable private guardian was available, and that the appointment of a public guardian was necessary or desirable. Sanders appealed, arguing that the probate court did not have jurisdiction to appoint a guardian for him because his situation did not comport with any basis for jurisdiction in the adult guardianship statute. The Supreme Judicial Court agreed and vacated the judgment of the probate court, holding that Me. Rev. Stat. tit. 18-A, 5-523(b)(3) did not vest the court with jurisdiction to appoint a nontemporary guardian for Sanders. View "In re Guardianship of Harold Sanders" on Justia Law

In 2011, Father and Mother were divorced pursuant to a divorce judgment. In 2015, the district court found Father in contempt for violating the divorce judgment. The court also denied Father’s motion to modify his child support obligation. The Supreme Court vacated in part and affirmed in part, holding (1) the court did not abuse its discretion by finding Father in contempt for nonpayment of child support for the years 2011, 2013 and 2014; (2) the court erred by finding that Father had not fully paid child support for 2012 and that he was in contempt for nonpayment for that year; (3) the court did not err by finding that there was no substantial change in circumstances warranting a modification of Father’s child support obligation; and (4) the court did not err by determining that Father was obligated to sell the marital home and to divide the proceeds pursuant to the terms of the divorce agreement. View "McCarthy v. Goroshin" on Justia Law

Camden National Bank filed a complaint for foreclosure against Ilene Weintraub. Weintraub brought several counterclaims against the bank, including violations of the Maine Consumer Credit Code, breach of contract, and a claim for intentional infliction of emotional distress, alleging that she suffered injuries as a direct and proximate result of the abuse conduct of the Bank’s collections department and an accusation of criminal conduct. The Bank filed a special motion to dismiss requesting dismissal of several claims based on Maine’s anti-SLAPP statute, but failing to request dismissal of the breach of contract claim. The superior court concluded that the anti-SLAPP statute prohibits selective dismissal of claims and that Weintraub met her burden of demonstrating a prima facie case of actual injury and causation. The Supreme Judicial Court affirmed, holding that the trial court (1) erred in holding that the anti-SLAPP statute did not allow for selective dismissal of some, but not all, of Weintraub’s counterclaims, but the error was harmless; and (2) did not err in concluding that Weintraub met her burden of showing prima facie evidence of causation. View "Camden Nat’l Bank v. Weintraub" on Justia Law

Plaintiff filed a complaint for negligence and wrongful death against Defendant, who owned and operated a guesthouse at which Plaintiff’s wife died. Plaintiff alleged that the guesthouse premises were unreasonably dangerous and that defects in the staircase of a bedroom were a proximate cause of his wife’s fatal injuries. The trial court entered summary judgment in favor of Defendant, concluding that Plaintiff failed to present a prima facie case that Defendant’s alleged negligence was a proximate cause of his wife’s fatal injuries. The Supreme Court affirmed, holding (1) the trial court did not err by disregarding certain statements in Plaintiff’s affidavit and the affidavit of his expert witness; and (2) the evidence could not not support a finding that Defendant’s allegedly unsafe premises bore a causal connection to Plaintiff’s wife’s injuries. View "Estate of Smith v. Salvesen" on Justia Law

In 2012, Nationstar Mortgage LLC filed a foreclosure action against Timothy Halfacre. The trial court entered judgment for Halfacre. Nationstar subsequently filed a new foreclosure action against Halfacre. The superior court concluded that the foreclosure action was barred by the doctrine of res judicata. On appeal, Nationstar asserted that it lacked standing to bring the action, and therefore, the action should be dismissed without prejudice. The Supreme Court vacated the trial court’s judgment and dismissed the case, holding that Nationstar lacked standing to foreclose on the mortgage. Further, the Court left to the trial court the determination of whether a sanction should be imposed in this matter. View "Nationstar Mortgage LLC v. Halfacre" on Justia Law

Lois Young filed a complaint claiming that her transfer of her home to her former foster child, Joseph Lagasse, and his wife was the result of undue influence and therefore should be voided. The trial court concluded Plaintiff did not meet her burden of establishing that the property transfer was improvident transfer of title within the meaning of the Improvident Transfers of Title Act, and therefore denied relief. The Supreme Court affirmed, holding (1) the superior court did not err by not applying a statutory presumption that a transfer of assets by an elderly, dependent person is a result of undue influence unless that person was represented by independent counsel at the time of the transfer; and (2) the record supported a finding that the transfer was not the result of undue influence. View "Young v. Lagasse" on Justia Law

Defendant entered a conditional plea of nolo contendere to the crime of operating after suspension. A judgment of conviction was entered accordingly. Defendant appealed, arguing that the lower court erred in denying his motion to suppress because the law enforcement officer’s decision to stop his vehicle was pretextual and the stop was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding that the record supported the court’s inferred finding that the stop was supported by a reasonable articulable suspicion of a threat to public safety, and therefore, the lower court did not err in denying Defendant’s motion to suppress. View "State v. Sasso" on Justia Law

This case involved a dispute primarily among siblings regarding the substance of and rights to their mother’s estate. Plaintiff commenced an action against Defendants for tortious interference with an expectancy of an inheritance. The superior court granted summary judgment in favor of Defendants, concluding that Plaintiff did not make a prima facie case for the causation element of his cause of action. The Supreme Judicial Court affirmed, holding that Plaintiff could not establish a prima facie case for tortious interference with an expectancy interest, and therefore, the trial court did not err in granting the motion for summary judgment in favor of Defendants. View "Cote v. Cote" on Justia Law

A divorce judgment was entered providing for the shared primary residence of Mother and Father’s child. The district court subsequently modified the judgment, which created a more complicated schedule of contact. Due to the frequent transitions between parental homes and tensions between her parents, the child became depressed. By the time she was almost eight years old, the child had a serious breakdown. While Mother’s and Father’s post-divorce motions were pending, the court ordered a less complex schedule. At the conclusion of the trial on the motions, the district court ordered that a similar schedule become part of the parties’ modified divorce judgment. The resulting judgment established primary residence of the child with Mother. Father appealed. The Supreme Court affirmed, holding that the record supported the court’s determination that establishing primary residence with Mother and modifying the schedule of contact was in the child’s best interest. View "Little v. Wallace" on Justia Law

In January 2012, after the death of John Gilbert, intestate probate proceedings were commenced. In November 2013, the probate court concluded that the relationship between Judith Gilbert, John’s widow, and Nathan Gilbert, John’s son from a prior relationship, had “risen to the level of causing concern” and ordered that it would supervise Judith’s distribution and settlement of the estate. In 2015, a court-appointed referee filed a report recommending a plan to distribute the estate. Judith objected to many of the report’s findings and recommendations. Nathan moved the court to adopt the report. The probate court did not hold a hearing regarding Judith’s objections and did not act on the report but, rather, continued to supervise Judith’s administration of the estate by entering orders. The Supreme Court vacated the order and remanded, holding that because the court had not held a hearing on Judith’s objections and acted on the report, the court erred by continuing to enter orders supervising the disposition of the estate. Remanded. View "In re Estate of Gilbert" on Justia Law