Justia Maine Supreme Court Opinion Summaries

Philip Barter hired Philip Tobin to produce a book encompassing Barter’s artistic works. The parties subsequently entered into a written agreement providing that Tobin would write the text for the book and setting forth the financial arrangements. Tobin drafted a manuscript of the book and gave Barter a draft of the manuscript, but Barter did not respond. Thereafter, Tobin filed a complaint alleging that Barter had breached the parties’ contract. The jury returned a verdict in favor of Tobin. The next day, the trial court granted Barter’s motion for a judgment as a matter of law, concluding that Tobin had failed to present sufficient evidence that the parties had a meeting of the minds necessary to form a legal contract. The Supreme Court reversed and remanded with directions to reinstate the jury’s verdict in favor of Tobin, holding (1) the trial court erred in issuing its judgment in favor of Barter as a matter of law; and (2) a jury rationally could have found that Barter had materially breached the contract by failing to respond to Tobin.View "Tobin v. Barter" on Justia Law

After a jury trial, Defendant was convicted of one count of gross sexual assault. On appeal, Defendant argued that the trial court committed obvious error by permitting the State to introduce evidence of his pre-arrest refusal to voluntarily submit to a warrantless collection of a DNA sample and to argue to the jury that it could infer consciousness of guilt from the refusal. The Supreme Court vacated the judgment, holding that the trial court committed obvious error in admitting evidence of Defendant’s refusal to submit to the warrantless search for the purpose of proving consciousness of guilt. Remanded.View "State v. Glover" on Justia Law

After a bench trial, Defendant was convicted of criminal trespass for entering a Rite Aid store six months after a police officer ordered Defendant not to be on the premises. Defendant appealed, arguing that the State failed to prove that he violated the criminal trespass statute because the officer was not “authorized” under the meaning of the statute to order Defendant not to enter the Rite Aid. The Supreme Court affirmed the judgment, holding that the evidence was sufficient for the fact-finder to rationally infer, beyond a reasonable doubt, that the officer was authorized by Rite Aid, and within the meaning of the criminal trespass statute, to order Defendant not to enter the Rite Aid store.View "State v. Sanchez" on Justia Law

After a jury trial, Defendant was convicted of two counts of gross sexual assault and suspended to twenty years imprisonment. On appeal, Defendant argued that the evidence was insufficient to sustain his convictions, that the prosecutor engaged in impermissible misconduct, and the trial court erred in determining his sentence. The Supreme Court vacated the judgments of conviction, holding (1) the prosecutor violated the state and federal Constitutions by eliciting testimony that Defendant did not return phone calls from police and by arguing to the jury that Defendant’s pre-arrest silence demonstrated consciousness of guilt, and the error seriously affected the fairness and integrity of the judicial proceedings; and (2) the prosecutor committed misconduct by vouching for witness credibility even after the court determined that the statements were impermissible, and the error was not harmless.View "State v. Lovejoy" on Justia Law

After Patrick Burrow filed a complaint for divorce from Rachel Burrow, the parties resolved all issues relating to parental rights and responsibilities. A trial was held on the disposition of the real property. The trial court entered a final order accepting the parties’ stipulated value of $310,000 of the martial home, finding that the parties’ equity in the property was $215,000, setting aside $75,00 of the equity as having been gifts to Rachel from her family, and dividing the remaining $140,000 equally. After an additional adjustment, the court distributed $77,500 of the equity to Patrick and $137,500 to Rachel. The Supreme Court vacated the judgment of the trial court and remanded, holding (1) the court’s judgment did not impermissibly have the effect of setting apart some portion of the marital equity in the real property as if it were nonmarital; and (2) the trial court erred its factual findings regarding the value of the gifts given to Rachel by her family, and therefore, the division of the equity between the parties must be decided anew. View "Burrow v. Burrow" on Justia Law

After nearly thirty years of marriage, Christine Starrett filed a complaint for divorce from Irven Starrett. In preparation for trial, the parties hired an expert to calculate the value of Irv’s Drywall, the parties’ privately owned business. The district court entered a divorce judgment that rejected the expert’s opinion and rejected Christine’s estimate and ultimately awarded Irven all of the parties’ interest in the business. The Supreme Court affirmed the divorce judgment, holding (1) the district court committed factual error in its valuation of Irv’s Drywall; but (2) the factual error did not affect Christine’s substantial rights in the ultimate division of the marital property or otherwise prejudice her. View "Starrett v. Starrett" on Justia Law

After a six-day jury trial, Defendant was convicted of gross sexual assault and sentenced to a term of twenty-four years. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit obvious error in denying Defendant’s access to immigration records pertaining to the victim’s mother; (2) the process used by the trial court to ensure that Defendant, who spoke Spanish, received adequate interpretation services at trial was appropriate and was not in error; and (3) the remainder of Defendant’s arguments on appeal were without merit.View "State v. Marroquin-Aldana" on Justia Law

Appellant was terminated from his employment as a registered nurse at a community hospital after a patient under Appellant’s care departed from the hospital, unescorted, into blizzard-like conditions and died less than 500 feet from the hospital’s entrance. After a two-day disciplinary hearing, the State Board of Nursing found Appellant violated several statutes and Board rules and revoked Appellant’s professional nursing license for two years. Appellant subsequently filed a petition for de novo judicial review in the district court. The district court concluded that it would not rehear the evidence presented to the Board and, after finding “competent evidence” on the record to support the Board’s findings, affirmed the Board’s decision to revoke Appellant’s license. The Supreme Court vacated the district court’s judgment, holding that the court erred in its interpretation and application of “de novo judicial review.” Remanded. View "Zablotny v. State Bd. of Nursing" on Justia Law

After a jury trial, Defendant was found guilty of murder and sentenced to forty-five years’ imprisonment. The Supreme Court affirmed the judgment and sentence, holding that the trial court did not err in (1) denying Defendant’s motion to suppress the evidence resulting from three searches of his residence by law enforcement officers; (2) allowing a prospective juror to serve on the jury after she disclosed during voir dire that she was once a victim of domestic violence; (3) denying Defendant’s motion to exclude certain physical evidence and failing to exclude expert and nonexpert testimony concerning the significance of that evidence; and (4) imposing a final sentence of forty-five years' imprisonment.View "State v. Diana" on Justia Law

Patrick Jackson and Sally McLeod were divorced in 2004. The contentiousness that began at the outset of the divorce action extended over a decade with continuing conflict and litigation, much of which centered around the parties’ three children. Prior to the judgment at issue in this appeal, McLeod provided the primary residence for all three children, and Jackson had visitation rights. McLeod filed a motion to modify the parental rights order. The court later held a hearing on McLeod’s motion to modify. Relying on incidents that occurred the summer prior to the hearing, the court implicitly concluded that a substantial change in circumstances had occurred and that it was in the youngest child’s best interest to eliminate overnight visitation with Jackson. The court then imposed a $1000 civil fine for Jackson’s “subterfuge” during one of the incidents. The Supreme Court vacated the judgment assessing the civil penalty and affirmed in all other respects, holding (1) the court lacked authority to impose the civil penalty; (2) the court did not err in modifying Jackson’s rights of contact; and (3) Jackson’s remaining arguments were without merit. View "Jackson v. MacLeod" on Justia Law