Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of robbery. Defendant proceeded to trial without representation after the trial court determined that Defendant had forfeited his right to counsel after threatening to cause serious bodily harm to one of his attorneys in the presence of another attorney, by his deliberate unwillingness to work with those attorneys’ predecessors, and by failing to show that he would work cooperatively with successor counsel. The Supreme Judicial Court affirmed the trial court’s decision to require Defendant to proceed to trial without legal representation, holding (1) in circumstances of egregious misconduct, an accused can forfeit his right to counsel, and in this case, the trial court did not err in concluding that Defendant’s conduct rose to the level that constituted a forfeiture; and (2) in the alternative, the record established that through his egregious misconduct, Defendant waived his right to counsel by implication. View "State v. Nisbet" on Justia Law

The beach easement dispute in this case concerned the intertidal area in front of oceanfront lots owned by Beverly and David Gravison, Sandra Titcomb, and Darlene and Lewis Edwards. The Gravisons filed a deed reformation complaint seeking to reform a deed to include the intertidal zone. Neighboring property owners counterclaimed seeking a declaratory judgment confirming the existence of deed easements over the oceanfront lots at issue. The superior court (1) denied the Gravisons’ reformation claim, (2) declared that the neighboring property owners held easements permitting recreational use of the beach located in front of the Edwardses’ and the Gravisons’ property, and (3) declared that neighboring property owners held easements in a perimeter path located on the properties owned by the Gravisons, Titcomb, and the Edwardses. The Supreme Court (1) affirmed the denial of the Gravisons’ complaint for deed reformation; (2) affirmed the superior court’s decision on all issues pertaining to the perimeter path; and (3) affirmed in part and vacated in part the court’s decision regarding the beach easements and clarified the judgment to reflect that the neighbors’ beach rights were limited to recreational activities reasonably related to bathing and boating. View "Gravison v. Fisher" on Justia Law

After Sloan’s Cove, LLC executed a power of sale foreclosure on Armand Vachon’s property, Vachon and Oceanic Inn, Inc. (collectively, Oceanic) filed suit claiming that Sloan’s Cove improperly conducted the sale. The trial court (1) dismissed Oceanic’s claims for breach of fiduciary duty and negligent infliction of emotional distress, and (2) granted summary judgment against Oceanic on its claims for breach of contract and accounting and in favor of Sloan’s Cove on its counterclaim seeking a declaration that its foreclosure by sale of the Oceanic Inn property was legal and effective. The Supreme Judicial Court affirmed as amended, holding that the trial court did not err in its judgment, but that the judgment must be amended to correct a clerical error. View "Oceanic Inn, Inc. v. Sloan's Cove, LLC" on Justia Law

Somerset County receives income generated by boarding federal prisons at the Somerset County Jail (SCJ). That income is used to support the jail budget. During fiscal year 2013, the County received more federal boarding revenue than anticipated. Without consulting with or receiving approval from the former State of Maine Board of Corrections, the County applied a portion of that surplus income to debt service for the cost to construct the SCJ facility. In response, the Board correspondingly reduced the amount of the County’s corrections funding from other sources. The County appealed. The superior court vacated the Board’s decision to withhold funding, concluding that pertinent legislation did not authorize the Board to adjust payments to the County as a result of the County’s unauthorized use of surplus federal boarding income. The Supreme Judicial Court vacated the superior court’s judgment and remanded for entry of judgment in favor of the Department of Corrections, as the party substituted for the Board, holding that the Board acted within its authority when it took action affecting the funding otherwise due to the County. View "Somerset County v. Dep’t of Corr." on Justia Law

After Father’s one-year-old child was hospitalized for ingesting a strip of Suboxone while in Father’s care, Father was removed from the home pursuant to a Department of Health and Human Services safety plan. Father was subsequently arrested and incarcerated. The district court ultimately terminated Father’s parental rights pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2). Father appealed, arguing that the district court impermissibly terminated his parental rights based on his incarceration and that the Department failed to make a meaningful effort at reunifying him with his child. The Supreme Judicial Court affirmed, holding (1) the district court properly found that the length of Father’s incarceration rendered him incapable of taking responsibility for the child within a time reasonably calculated to meet the child’s needs; and (2) the district court was not required to address the extent of the Department’s reunification efforts in its finding that Father is unfit. View "In re Daphne" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence and violating a condition of release. Defendant was sentenced to a term of sevens days in county jail. On appeal, Defendant argued that the trial court erred in denying his motion to suppress and, at trial, in admitting evidence of his blood-alcohol level derived from a sample of his blood that was seized without a search warrant. The Supreme Judicial Court affirmed, holding that the trial court did not err in denying the motion to suppress, as there were exigent circumstances at the time of the blood draw negating the requirement for a search warrant. View "State v. Arndt" on Justia Law

After a trial, the district court terminated the parental rights to Mother, the mother of Aiden and Benjamin, and Father, the father of Carl, Daryl, and Benjamin. On appeal, Father argued that the district court erred in finding him unfit because the Department of Health and Human Services failed to comply with its statutory rehabilitation and reunification responsibilities. Mother, in turn, argued that the court erred in weighing the evidence before it. The Supreme Court affirmed, holding that, as to each child, the court found at least one ground of parental unfitness supported by clear and convincing evidence and that there was ample evidence to support the court’s finding that termination of each parent’s parental rights was in the children’s best interests. View "In re Aiden" on Justia Law

The two children at issue in this case lived with their grandmother both before and after their mother died. The grandmother filed petitions seeking guardianship of the children alleging that she was a de facto guardian of the children and that the children’s father had demonstrated a lack of consistent participation with the children. After receiving notice of the guardianship petitions, the father moved the children from their home in Maine to live with him in Florida. The Maine probate court subsequently appointed the grandmother the limited permanent guardian of the children. The Supreme Court affirmed the judgment to the extent that it appointed the grandmother as the children’s limited guardian, holding that the probate court did not err in finding that the grandmother was entitled be named the children’s guardian based on her status as the children’s de facto guardian, the father’s lack of consistent participation, and the temporarily in tolerable living situation created by the father. Remanded to the probate court with instructions to specify which duties and powers are granted to the limited guardian and which parental rights and responsibilities are retained by the father. View "In re Guardianship of Abigail Doe" on Justia Law

Paul Galipeau was involved in a fatal accident while riding his motorcycle. Galipeau and his wife were insured under four vehicle policies issued by State farm, one on the motorcycle and the others covering three different vehicles. Each of the policies provided uninsured motorist (UM) coverage with a per-person limit of $100,000. The Estate demanded from State Farm the aggregate of each policy’s UM coverage limit, less the $50,000 recovered from the tortfeasor. State Farm paid the differential between the motorcycle policy UM limit and the amount already recovered by the Estate and otherwise refused the demand. The Estate subsequently sued State Farm for wrongful denial of coverage. The superior court entered judgment for State Farm, ruling that coverage under the three non-motorcycle policies was precluded by an “other-owned-vehicle” exclusion that each policy contained. The Supreme Court affirmed, holding that the superior court did not err in entering summary judgment for State Farm on the ground that the other-owned-vehicle exclusion in the four policies precluded coverage under the three non-motorcycle policies. View "Estate of Galipeau v. State Farm Mut. Auto. Ins. Co." on Justia Law

In this case, the Supreme Court considered when a municipal agency’s decision constitutes a final action subject to immediate judicial review. The owner of the Camden Harbour Inn applied to the Town of Camden for authorization to increase the number of guest rooms and parking spaces for the Inn and to reduce the number of seats at the Inn’s restaurant. The Zoning Board of Appeals (ZBA) granted a special exception permit subject to conditions and allowed the Inn to proceed to the Planning Board for site plan review. Susan Bryant, an abutter, appealed the ZBA’s decision to the superior court before site plan review could occur. The superior court affirmed the ZBA’s decision. The Supreme Court vacated the judgment of the superior court and remanded for dismissal of Bryant’s complaint, holding that, while the Town’s Zoning Ordinance expressly provided for Bryant’s appeal from the grant of the preliminary special permit, the ZBA’s decision was not a final action subject to appellate review in the courts because additional process was required by the Town’s Ordinance before a final decision on the Inn’s proposed changes is reached. View "Bryant v. Town of Camden" on Justia Law