Justia Maine Supreme Court Opinion Summaries

After a jury-waived trial, Defendant was convicted of domestic violence assault and assault. The convictions stemmed from an altercation with Defendant’s ex-girfriend and his stepdaughter. Defendant appealed, arguing that the trial court erred in finding that the State presented sufficient evidence to disprove Defendant’s self-defense justification beyond a reasonable doubt. The Supreme Judicial Court affirmed, holding that, viewed in the light most favorable to the State, competent evidence supported the trial court’s ultimate finding that the State disproved Defendant’s self-defense justification beyond a reasonable doubt. View "State v. Fletcher" on Justia Law

After a jury trial, Defendant was convicted of tampering with a victim, aggravated furnishing of scheduled drugs, and endangering the welfare of a child. Defendant appealed, arguing that the trial court erred by denying her request that the court instruct the jury on the statutory defense of duress. The Supreme Judicial Court affirmed, holding that the court did not err in declining to instruct the jury on the statutory defense of duress as to any of the three charges because the jury could not have found facts necessary to find that Defendant’s conduct was the product of duress. View "State v. Gagnier" on Justia Law

At issue in this case was an order of the Maine Public Utilities Commission approving an alternative rate plan (ARP) for Bangor Gas Company, LLC. The Maine Office of the Public Advocate (OPA) and Bucksport Mill, LLC appealed from the Commission’s order. The Supreme Judicial Court affirmed, holding (1) the Commission did not abuse its discretion or exceed its statutory authority in calculating the APR initial rate base by utilizing an unimpaired, “original cost” valuation of Bangor Gas’s assets rather than the impaired “acquisition cost” incurred by Bangor Gas’s parent company; and (2) the OPA’s argument that the Commission abused its discretion by including in its revenue requirement calculation a portion of the Bangor Gas’s regulatory proceeding expenses amortized over five years need not be addressed because the Commission’s decision to include the regulatory proceeding expenses in its revenue requirement analysis had no impact on its decision to approve the ARP. View "Office of Pub. Advocate v. Pub. Utils. Comm’n" on Justia Law

Kevin Collins, a prison inmate, filed three grievances against the Department of Corrections relating to food services and the prison’s telephone system. The Department denied the grievances. Collins subsequently filed a petition for judicial review of a final agency action. The trial court ultimately dismissed Collins’s petition as untimely. Collins filed a notice of appeal accompanied by an application to proceed without payment of fees, thus requiring Collins to file a certified copy of his account statement for the six months preceding his appeal. Collins did not file his account statement in a timely manner. The trial court waived the appellate filing fee. The Department appealed from the order waiving the filing fee and filed a motion to dismiss Collins’s appeal for failure to file a new account statement for the six months preceding this appeal, arguing that Collins had failed to perfect his appeal. The Supreme Judicial Court (1) dismissed Collins’s appeal on the grounds that Collins failed to comply with the timing requirements of the Maine Rules of Appellate Procedure and had failed to perfect his appeal; and (2) dismissed as moot the Department’s appeal from the order waiving Collins’s appellate filing fee. View "Collins v. Dep’t of Corr." on Justia Law

While he was an inmate, Defendant was charged with ten counts of assaulting an officer. Defendant was found not criminally responsible by reason by mental disease or defect and was ordered committed to the custody of the Commissioner of the Department of Health and Human Services (DHHS). Defendant’s prison sentence was tolled while he remained committed. Approximately five years later, the superior court ordered Defendant to be discharged from DHHS custody, finding by clear and convincing evidence that he no longer suffered from a mental disease or defect. Defendant was subsequently remanded to the custody of the Department of Corrections to serve the remainder of his prison sentence. The Supreme Court affirmed, holding that the evidence supported the trial court’s finding, by clear and convincing evidence, that Defendant’s dangerousness was not the result of a mental disease or defect and that, therefore, DHHS could no longer maintain Defendant in its custody. View "James v. State" on Justia Law

The district court concluded that Mother placed her child in circumstances of jeopardy, finding that Mother’s actions caused at least a threat of serious harm to the child and that the child had been deprived of necessary health care. As part of the child protection order it issued granting custody to the Department of Health and Human Services, the court ordered the Department to approve vaccinations for the child over Mother’s objections. The Supreme Court affirmed, holding (1) the evidence was sufficient to support a finding of jeopardy; and (2) the district court did not err by ordering the Department to approve all vaccinations for the child that are deemed essential by a pediatrician. View "In re Z.S." on Justia Law

Defendant pleaded guilty in federal court to sexual exploitation of a child and possession of child pornography. Before sentencing, a state grand jury indicted Defendant on thirteen counts of gross sexual assault. Defendant pleaded not guilty to all of the gross sexual assault charges. After the federal district court sentenced Defendant, Defendant filed a motion to dismiss the State’s indictments for gross sexual assault, arguing that the State’s prosecution subjected him to double jeopardy. The trial court denied the motion to dismiss. The Supreme Judicial Court affirmed, holding (1) even if the State’s current prosecution subjects Defendant to the risk of being punished twice for the same conduct, such duplicative punishment is constitutional when, as in this case, the punishments are imposed by separate sovereigns; and (2) there is no evidence to sustain Defendant’s contention that an exception to the “dual sovereignty” doctrine of double jeopardy jurisprudence applied in this case. View "State v. Hoover" on Justia Law

Bank of America brought this foreclosure action against Marianne Gregor. Homeward Residential, Inc. was later substituted as plaintiff. The district court entered judgment for Gregor, determining that Homeward Residential had not established that it had standing to foreclose on the mortgage. In its judgment, the court stated that “[t]he parties may relitigate issues discussed herein in a future action.” The Supreme Judicial Court vacated the judgment, holding that the district court (1) correctly determined that Homeward Residential lacked standing to pursue the foreclosure claim; but (2) erred when it made findings and entered judgment for Gregor rather than dismissing the action for lack of standing. Remanded for an entry of a dismissal without prejudice. View "Homeward Residential, Inc. v. Gregor" on Justia Law

Three-year-old N.O. handled her parents’ loaded firearm and accidentally shot herself while her older siblings, P.O. and J.O., were present in the home. Mother was at work and Father was doing other things in the home at the time of the accident. After the district court entered a jeopardy order, the Department petitioned for termination of the parents’ parental rights. After a hearing, the district court entered its judgment terminating each parent’s parental rights, finding that termination was in the best interests of the children. The Supreme Court affirmed, holding that the district court did not err in its findings of unfitness as to both Mother and Father and in terminating their parental rights. View "In re P.O." on Justia Law

Pamela Jensen filed for divorce from Larry Jensen after almost thirty-five years of marriage. After attending mediation, the parties entered into a settlement agreement that purported to distribute all of the marital and nonmarital property and debts. Pamela subsequently filed a motion to set aside the mediated agreement, arguing that the mediated agreement and proposed divorce judgment were “manifestly unjust.” The family law magistrate denied Pamela’s motion and, that same day, signed the proposed divorce judgment. The district court adopted the magistrate’s decision and the divorce judgment. The Supreme Judicial Court vacated the judgment, holding that, where Pamela contested the terms of the agreement before the entry of a final judgment and objected to the proposed divorce judgment, and where this matter did not involve minor children or child support, the magistrate did not have jurisdiction to enter a final divorce judgment. Rather, once the matter became contested, it should have been referred to a district court judge for a ruling on Pamela’s motion. Remanded. View "Jensen v. Jensen" on Justia Law