Justia Maine Supreme Court Opinion Summaries

This case arose from disputes regarding the permissible uses of an easement that burdened the land owned by Charles Wardwell and benefitted and abutting parcel owned by John and Corie Duggins. Wardwell filed a complaint requesting that the superior court declare that the Dugginses’ activities exceeded the scope of the easement. The court declared in part that the scope of the easement included hunting and recreational activity. Wardwell then moved to amend the judgment by excluding the terms “hunting and recreation” from the declaration of the scope of the easement. The superior court denied the motion. The Supreme Judicial Court affirmed, holding that the superior court did not err by finding that hunting and recreation were uses contemplated by the parties to the original conveyance and in denying Wardwell’s motion to amend the judgment to exclude those uses from the scope of the easement. View "Wardwell v. Duggins" on Justia Law

After a jury trial, Defendant was convicted of criminal threatening. Before trial, Defendant filed a motion to suppress statements he had made after police officers stopped his vehicle, took his license and registration, and asked him to wait for a detective to arrive. The suppression court granted the motion in part but denied it as to the statements Defendant made before he was placed in handcuffs and arrested, holding that Defendant was not in custody until he was placed in handcuffs and that after he was handcuffed he did not waive his Miranda rights. Defendant appealed, arguing that the trial court erred by declining to suppress the statements that he made to the detective before his formal arrest. The Supreme Court vacated the judgment of conviction and vacated the suppression order in part, holding that Defendant was in custody when he responded to the detective’s questions and accusations, and because he was in custody when he made incriminating statements without the benefit of Miranda warnings, those statements were improperly admitted at trial. Remanded. View "State v. King" on Justia Law

In 2014, Defendant entered a conditional guilty plea to operating under the influence (OUI), elevated to a Class C felony by two prior convictions for operating under the influence. Defendant appealed, asserting that his 2013 OUI conviction - one of the two convictions that enhanced his 2014 charge - was obtained in violation of his Sixth Amendment right to counsel, and therefore, the trial court erred in denying his motion to strike that conviction from the indictment. The Supreme Judicial Court affirmed, holding that Defendant failed to meet his burden on collateral attack of demonstrating that he did not knowingly and intelligently waive his right to counsel. View "State v. Kennedy" on Justia Law

After Child’s mother died, Child’s maternal grandparents (Grandparents) petitioned for coguardianship of Child, alleging that Father had never provided direct care for Child, was unable to care for her, and had demonstrated a lack of consistent participation in Child’s life. The probate court court granted the petition for Child’s guardianship as to the maternal grandmother and denied it as to the maternal grandfather. The Supreme Judicial Court affirmed, holding that the evidence supported the probate court’s conclusions that Father demonstrated a lack of consistent participation in Child’s life and that Father remained unable to care for Child at the time of the hearing on the petition. View "In re Guardianship of Thayer" on Justia Law

In 2008, Richard and Suzan Collins were divorced. In 2009, the court issued an amended judgment that contained an order of enforcement. In 2014, the court held Richard in contempt for failing to comply with the payment obligations created by the 2009 order. Two months after the court issued the contempt order, Richard filed a petition for Chapter 7 bankruptcy. Later that year, the Bankruptcy Court issued a discharge in bankruptcy. Suzan then filed a request for a show cause hearing, asserting that Richard had not made the payments required by the 2014 contempt order. Richard moved to dismiss Suzan’s request for the show cause hearing on the grounds that, aside from his child support debt, all of his financial obligations had been discharged in the bankruptcy action. After a show cause hearing, the district court denied Richard’s motion to dismiss and confirmed his payment obligations as ordered in the contempt order. The Supreme Judicial Court affirmed, holding that Richard’s obligations under the divorce judgment were statutorily insulated from a post-judgment bankruptcy discharge, and Richard remained liable to Suzan and for payments to a third-party creditor. Therefore, the district court did not err by enforcing the contempt order that pre-dated the bankruptcy discharge. View "Collins v. Collins" on Justia Law

After a jury trial, Defendant was convicted of kidnapping and murdering a fifteen-year-old girl. The Supreme Judicial Court affirmed, holding (1) the trial court did not err by admitting nonexpert opinion testimony regarding handwriting to prove that Defendant wrote a document admitting to the crime, and even if the admission of the testimony was in error, it is highly probable that any error would have been harmless; and (2) there was no error, much less an error so prejudicial that it deprived Defendant of his right to a fair trial, in the State’s repeated mention of the jurors’ “common sense” in its closing argument. View "State v. Dube" on Justia Law

After a jury trial, Defendant was convicted of kidnapping and murdering a fifteen-year-old girl. The Supreme Judicial Court affirmed, holding (1) the trial court did not err by admitting nonexpert opinion testimony regarding handwriting to prove that Defendant wrote a document admitting to the crime, and even if the admission of the testimony was in error, it is highly probable that any error would have been harmless; and (2) there was no error, much less an error so prejudicial that it deprived Defendant of his right to a fair trial, in the State’s repeated mention of the jurors’ “common sense” in its closing argument. View "State v. Dube" on Justia Law

Defendant entered a conditional guilty plea to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained from the stop of his vehicle by a game warden. The suppression court found that the warden stopped Defendant’s vehicle after making an “unnecessarily wide” right turn into the approaching lane of another road. The Supreme Court affirmed, holding that the warden’s testimony was sufficient to support the suppression court’s finding that the warden had a reasonable articulable suspicion that Defendant had committed a traffic violation and that the warden’s subjective suspicion was objectively reasonable under the circumstances. View "State v. Simmons" on Justia Law

Defendant entered a conditional guilty plea to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained from the stop of his vehicle by a game warden. The suppression court found that the warden stopped Defendant’s vehicle after making an “unnecessarily wide” right turn into the approaching lane of another road. The Supreme Court affirmed, holding that the warden’s testimony was sufficient to support the suppression court’s finding that the warden had a reasonable articulable suspicion that Defendant had committed a traffic violation and that the warden’s subjective suspicion was objectively reasonable under the circumstances. View "State v. Simmons" on Justia Law

Darling’s Auto Mall is a franchisee of General Motors LLC (GM) and and authorized dealer. Darling’s filed two small claims actions in district court alleging that it had been underpaid by GM for certain warranty repairs in violation of the Business Practices Between Motor Vehicle Manufacturers, Distributors and Dealers Act (Dealers Act). The district court ruled in favor of Darling’s on both small claims. GM appealed and requested a jury trial de novo. The superior court granted GM’s request. After a jury trial, the superior court entered a judgment in favor of GM. The Supreme Judicial Court affirmed, holding (1) the superior court’s decision to grant a jury trial de novo was not an appealable determination; (2) the trial court did not err in denying Darling’s motion for judgment as a matter of law; and (3) the trial court properly rejected Darling’s proposed jury instructions. View "Darling's Auto Mall v. General Motors LLC" on Justia Law