Justia Maine Supreme Court Opinion Summaries

In 2003, John Doe XLVI pleaded guilty to and was convicted of possession of sexually explicit material. When Doe was sentenced, possession of sexually explicit material was not a sex offense requiring registration under Maine’s Sex Offender Registration and Notification Act of 1999 (SORNA), and therefore, Doe was not ordered to comply with SORNA. Possession of sexually explicit material was subsequently added to the list of sex offenses. In 2009, the Legislature amended SORNA to provide that a duty to register “is not triggered by a court determination, but by and upon notification.” In 2012, Doe received a notice of the duty to register. Doe filed this action seeking to enjoin the State from pursuing criminal charges against him for failing to register, alleging, inter alia, that SORNA was an invalid bill of attainder. The superior court rejected Doe’s challenges. The Supreme Court vacated the judgment of the trial court, holding that SORNA is punitive as to offenders who were not sentenced to comply with SORNA when SORNA registration was part of sentencing and who were subsequently subjected to SORNA registration when their earlier offenses were added to the statutory list of sex offenses and registration was removed from sentencing. View "John Doe XLVI v. Anderson" on Justia Law

Jeffrey Wyman was charged with operating under the influence (OUI) and, after a jury trial, found not guilty. Jeffrey and his son, David Wyman (Defendant), both testified during the OUI trial. The instant perjury case stemmed from this testimony. Both Defendant and his father were indicted for perjury. After a jury trial, Defendant was found guilty of perjury. The Supreme Court affirmed, holding (1) because the State presented proof of the elements of perjury with respect to David’s testimony, the evidence was sufficient to support Defendant’s conviction; and (2) the trial court did not abuse its discretion in admitting cell phone billing records over Defendant’s objection. View "State v. Wyman" on Justia Law

After a jury trial, Defendant was convicted of perjury. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by allowing the State to introduce testimony regarding Defendant’s silence following his arrest for operating under the influence (OUI) and by allowing the State to refer to this testimony during closing argument; (2) Defendant failed to establish that the trial court abused its discretion in allowing a police officer to testify to his opinion that “there were lies told” during Defendant’s trial for OUI, at which Defendant was acquitted, or that the opinion was prejudicial to him; and (3) admitting the testimony of a Verizon employee about the contents of Defendant’s cell phone billing record that the State offered as the testimony of a custodian of records. View "State v. Wyman" on Justia Law

Following a jury trial, Defendant was convicted of burglary, theft by unauthorized taking, and violation of a condition of release. The court imposed an aggregate sentence of seven years’ imprisonment. On appeal, Defendant argued, inter alia, that the trial court effectively prevented him from testifying when, prior to trial, it reserved ruling on the extent to which the State would be permitted to impeach his potential testimony. The Supreme Court affirmed, holding (1) the trial court did not obviously err in declining to give Defendant a pretrial ruling; and (2) the evidence was sufficient to support the jury’s verdict. View "State v. Perkins" on Justia Law

James Dickau was injured when he was struck by a vehicle driven by Irida Macomber. At the time of the accident, Dickau was covered by two insurance policies - a Dairyland Insurance Company policy and a Vermont Mutual personal umbrella policy. Dickau settled his claim against Macomber for her policy limit and also settled his claim for uninsured motorist benefits with Dairyland. Dickau then sought a declaratory judgment that his umbrella policy with Vermont Mutual provides for uninsured motorist coverage, and alternatively, that Vermont Mutual was required to provide uninsured motorist coverage under statute. The superior court granted Vermont Mutual’s motion for summary judgment. The Supreme Court affirmed, holding (1) Dickau’s umbrella policy with Vermont Mutual itself unambiguously provides no UM coverage; and (2) Maine’s UM statute does not require Vermont Mutual to provide UM coverage in the umbrella policy. View "Dickau v. Vermont Mut. Ins. Co." on Justia Law

In 2013, pursuant to the Freedom of Access Act (FOAA), Phillip Bowler requested a copy of the Attorney General’s investigative file concerning a death that occurred in 1953. The Deputy Attorney General denied Bowler access to the file on the ground that it was designated confidential by statute. Bowler appealed to the superior court. The superior court denied the appeal. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the file was made confidential by statute; (2) the Attorney General did not waive the statutory confidentiality of the file by releasing a copy to the decedent’s family; and (3) Defendant’s argument that releasing the file to a family member but not to him violated his constitutional right to equal protection failed. View "Bowler v. State" on Justia Law

Pisgah Mountain, LLC applied to the Town of Clifton Planning Board for approval to construct and operate a wind energy project. Peter and Julie Beckford, who own land adjacent to the proposed development site, timely appealed the Board’s decision to the Town’s Zoning Board of Appeals (ZBA). The ZBA denied the appeal. Thereafter, the Beckfords filed a complaint in superior court pursuant to Me. R. Civ. P. 80B. Pisgah and the Town moved to dismiss the Beckfords’ complaint on the ground that it was filed outside of the forty-five-day appeal period. The superior court denied the motion to dismiss, concluding that the forty-five-day appeal period started when the ZBA issued its written findings and decision and not on the day the ZBA voted to deny the appeal. The court then vacated the Board’s decision to approve the permit. The Supreme Court vacated the judgment of the superior court, holding that the statutory appeal period commenced with the ZBA’s public vote, and therefore, the Beckfords’ Rule 80B appeal was untimely filed. View "Beckford v. Town of Clifton" on Justia Law

The Bank of Maine filed a complaint seeking foreclosure of Defendant’s primary residence. Defendant failed to file a timely answer, and the superior court later entered Defendant’s default. Defendant responded to the complaint and requested mediation on the date default was entered. The court granted summary judgment to the Bank and entered judgments of foreclosure that included legal fees. Defendant appealed, arguing that the time limit established by Me. R. Civ. P. 93 improperly limits a defendant’s substantive right to mediation. The Supreme Court affirmed, holding (1) Rule 93 is not an improper limitation of the substantive rights of litigants; and (2) because Defendant did not request mediation pursuant to Rule 93 in a timely manner, the court did abuse its discretion in denying Defendant’s request for mediation. View "Bank of Maine v. Peterson" on Justia Law

Robert Nadeau filed a complaint for protection from harassment against Lynnann Frydrych, alleging that Frydrych had engaged in acts of harassment against him since the end of their personal relationship. Frydrych moved to dismiss for failure to state a claim and sought attorney fees on the basis that the complaint was frivolous and contained unwarranted personal attacks on her. The district court dismissed the complaint, concluding that Nadeau had not sufficiently alleged harassment, and awarded Frydrych attorney fees and costs. The Supreme Court vacated the judgment, holding that the allegations in the complaint were sufficient to overcome a motion to dismiss, and because the complaint was not frivolous, the court abused its discretion by awarding Frydrych attorney fees and costs. View "Nadeau v. Frydrych" on Justia Law

Lawrence Ireland and Brooke Tardiff were divorced by a divorce judgment entered by the district court. The district court later found Ireland in contempt for his failure to make timely payment to Tardiff of the judgment amount. Ireland moved to reconsider and moved for further findings regarding his finances and ability to make the payments as ordered. The court denied the motion and found that Ireland was capable of meeting the payments as outlined in the contempt order. The Supreme Court affirmed, holding that the district court (1) properly found that Ireland had the ability to comply with the court order, at least in part, and failed or refused to comply with that order; and (2) thus did not abuse its discretion in finding Ireland in contempt. View "Ireland v. Tardiff" on Justia Law