Justia Maine Supreme Court Opinion Summaries

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

After a jury trial, Appellant was convicted of one count of gross sexual assault and three counts of endangering the welfare of a child. Appellant appealed, arguing that the trial court erred in excluding a licensed counselor’s proposed testimony concerning Appellant’s experience of abuse and its effect on her decision-making, as the testimony was relevant to the defense of involuntary conduct. The Supreme Court affirmed, holding that the trial court did not err in determining that the counselor’s background and his expected testimony regarding Appellant’s history of being abused was not relevant to the defense of involuntariness. View "State v. Morrison" on Justia Law

Appellant was charged with improperly accepting more than $109,003 in benefits from MaineCare by misrepresenting the composition of her household. After a jury-waived trial, Appellant was convicted of one count of theft by deception. Appellant appealed, arguing that the State did not prove beyond a reasonable doubt that her deception resulted in the taking of the property of another and that the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding that there was sufficient evidence to find that Appellant committed theft by deception when she intentionally misrepresented that her two minor children lived with her fifty percent or more of the time. View "State v. Hodsdon" on Justia Law

Brenda Freeman was injured in a work-related accident in 2007. Freeman returned to work but in a lower-paying position. Because of the decrease in her wages, Freeman received partial incapacity benefit payments. In 2011, Freeman suffered a second work-related injury. During Freeman’s period of incapacity, her employer paid 100 percent partial incapacity benefits based on the 2007 injury. Freeman filed a petition for award of compensation claiming that although she was already receiving benefits that equaled the maximum compensation rate as a result of her 2007 injury, she was eligible for additional compensation for the same period as a result of her 2011 injury. The hearing officer concluded that Freeman was ineligible for compensation beyond the statutory maximum benefit, regardless of the number of injuries. The Workers’ Compensation Board Appellate Division affirmed. The Supreme Judicial Court affirmed, holding that the hearing officer correctly construed the statutory maximum benefit provision of the Workers Compensation Act as a total ceiling on the potential benefits available to an injured employee, regardless of the number of injuries the employee suffers. View "Freeman v. NewPage Corp." on Justia Law

This case arose from the revocation of a building permit previously granted to R. Bruce Montgomery and Wanda Haddock (collectively, Montgomery). Montgomery, represented by Judy A.S. Metcalf and William V. Ferdinand Jr. (collectively, the Eaton Peabody attorneys), appealed the revocation of the permit, contesting the revocation of the part of the permit dealing with the construction of a garage. The Georgetown Planning Board left in place a stop-work order on the construction of the garage. Montgomery subsequently hired attorney Clifford H. Goodall to assist him in his attempts to apply for a building permit, without success. Montgomery filed a legal malpractice complaint against the Eaton Peabody attorneys. The superior court dismissed five of the six counts of the complaint. Montgomery subsequently filed a second amended complaint raising legal malpractice claims against Goodall. The superior court granted summary judgment in favor of Goodall. The Supreme Judicial Court affirmed, holding that the superior court (1) properly granted the Eaton Peabody attorneys’ motion to dismiss counts one through five of Montgomery’s complaint; and (2) did not abuse its discretion in denying Montgomery’s motion to file a third amended complaint made three years after the commencement of the suit. View "Montgomery v. Eaton Peabody, LLP" on Justia Law

In 2015, the district court entered a judgment of divorce and parental rights and responsibilities regarding the minor son of Husband and Wife. Husband appealed, arguing that the district court erred in determining his gross income and abused its discretion in distributing the parties’ marital property and awarding spousal support. The Supreme Court (1) vacated the court’s child support order and underlying gross income determination, as the divorce judgment contained no findings regarding Husband’s income, and therefore, the Court could not decide whether the district court’s findings were clearly erroneous; (2) vacated the order of spousal support, as the determination of Husband’s income provides a foundation for any award of spousal support; and (3) vacated the order distributing the parties’ property, as the district court must consider the determination of Husband’s income in crafting an equitable distribution of the parties’ assets and liabilities and must consider the consequences of its distributive order in assessing any award of spousal support. View "Ehret v. Ehret" on Justia Law

After a jury trial, Defendant was convicted of two counts of criminal restraint by a parent. Defendant appealed, asserting that the trial court erred by failing to declare a mistrial sua sponte after Defendant’s mother testified that she had visited Defendant in jail. Specifically, Defendant argued that the testimony undermined the fairness of the fact finding process by creating an impression in the jurors’ minds of Defendant’s guilt. The Supreme Court affirmed the conviction, holding that Defendant’s mother’s brief statement at trial likely did not have any effect, much less a prejudicial effect, on Defendant’s right to a fair trial. View "State v. Retamozzo" on Justia Law

Arthur Murdock, then a lieutenant with the Maine State Police, was injured when his cruiser was struck by another vehicle after Martin Thorne indicated that Murdock could turn in front of him into an intersection. Murdock filed a four-count complaint alleging negligence against Castigliola and Thorne and seeking uninsured motorist coverage from the Maine Department of Public Safety (DPS). The superior court granted the motions for summary judgment filed by both DPS and Thorne. Murdock appealed, and DPS cross-appealed. The Supreme Judicial Court dismissed the appeals, holding that the superior court improvidently granted Murdock’s motion to enter final judgment on Murdock’s claims against Thorne and DPS pursuant to Me. R. Civ. P. 54(b)(1). View "Murdock v. Thorne" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer. Defendant appealed, arguing that the trial court erred in finding that the State had met its burden to demonstrate the corpus delicti to allow the admission of evidence of Defendant’s out-of-court incriminating statements. The Supreme Judicial Court affirmed, holding that the trial court did not err when it concluded that the State had presented sufficient evidence to support a substantial belief that someone had stolen a package sent to the victim and, on that basis, admitted evidence of Defendant’s out-of-court inculpatory statements. View "State v. Poulin" on Justia Law

In 2008, Defendant pleaded guilty to theft, and in 2009, Defendant pleaded guilty to trafficking in a schedule Z drug. Defendant was ordered to pay fines in both cases. In 2014, Defendant was arrested for nonpayment of the fines. Defendant was subsequently committed to jail pursuant to Me. Rev. Stat. 17-A 1304(3) for intentionally or knowingly refusing to pay the fines assessed against him. Defendant appealed. The Supreme Judicial Court dismissed the appeal because the section 1304 hearing was a post-conviction proceeding, and Defendant’s sole avenue for appeal was through post-conviction review in the superior court. View "State v. Hayes" on Justia Law