Justia Maine Supreme Court Opinion Summaries

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

The trial court entered summary judgment in favor of Defendants on Plaintiff’s claims for wrongful use of civil proceedings and abuse of process. Plaintiff appealed, arguing that the trial court erred in concluding that Plaintiff failed to establish a prima facie case for each element of both causes of action. The Supreme Judicial Court affirmed but noted that the trial court would have been well within its discretion to have granted a summary judgment in favor of Defendant based solely on Plaintiff’s failure to comply with the requirements of Me. R. Civ. P. 56(h), or to have denied summary judgment altogether based on the manner in which both parties availed themselves of the summary judgment process. View "First Tracks Invs., LLC v. Murray, Plumb & Murray" on Justia Law

The Workers’ Compensation Board imposed a $30,000 penalty on Nale Holyoke and his construction company (collectively, Holyoke) for violating the insurance coverage requirements of the Workers’ Compensation Act (WCA). The Workers’ Compensation Board Appellate Division vacated the Board’s imposition of penalties on Holyoke. The Supreme Judicial Court affirmed, albeit for a different reason than that expressed by the Appellate Division, holding that Holyoke complied with Me. Rev. Stat. 39-A, 401 and 403 by maintaining workers’ compensation policies that would have provided compensation to any worker entitled to benefits, and therefore, Holyoke complied with the coverage requirements of the WCA. View "Workers Comp. Bd. Abuse Investigation Unit v. Nate Holyoke Builders, Inc." on Justia Law

After a formal investigation, the Commission on Governmental Ethics and Election Practices determined that the National Organization for Marriage (NOM) - a national nonprofit advocacy corporation “dedicated to preserving the institution of marriage as between one man and one woman” - was a “ballot question committee” and was therefore subject to and in violation of the registration and reporting requirements of Me. Rev. Stat. 21-A, 1056-B. The business and consumer docket denied NOM’s petition for review. NOM filed a petition for review of the Commission’s decision, accompanied by a motion for a stay pending the resolution of its appeal. The trial court denied NOM’s request for a stay. NOM then filed a petition with the Supreme Judicial Court seeking “clarification” that the Commission’s decision was automatically stayed or, alternatively, seeking a stay pursuant to the Court’s inherent power to grant a stay. The Supreme Judicial Court denied NOM’s motion for a stay, holding (1) the Commission’s determination is not automatically stayed pending appeal pursuant to Me. R. Civ. P. 62(e); and (2) the Court declines to stay the Commission’s decision pursuant to its inherent equitable authority. View "Nat’l Org. for Marriage v. Comm’n of Governmental Ethics & Elections Practices" on Justia Law

Husband filed a divorce action in Maine. At the time, there was an action for child custody and child and spousal support pending in the Virginia courts that was filed by Wife. Wife moved to dismiss Husband’s action. The Maine district court stayed the divorce proceedings and left to be determined whether the action would be dismissed because a party filed a divorce action in Virginia or whether the action would remain pending because neither party filed in Virginia or the Virginia court declined jurisdiction. The Supreme Judicial Court dismissed Father’s appeal, concluding that this appeal was interlocutory and not subject to any exception to the final judgment rule. View "Willey v. Willey" on Justia Law