Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of intentional or knowing murder and sentenced to seventy years imprisonment. Defendant appealed, arguing, inter alia, that the trial court violated his right to confront witnesses by admitting medical examiner testimony because the testimony relied in part on an autopsy report created by a different medical examiner who did not testify at trial. The Supreme Court affirmed, holding (1) pursuant to State v. Mitchell, the admission of the medical examiner’s testimony was not a violation of the Confrontation Clause; and (2) Defendant’s remaining assertions of error were unavailing.View "State v. Mercier" on Justia Law

Kennebec County participated in the Maine Public Employees Retirement System (MPERS), and at all times relevant to this appeal, eligible County employees had the option of joining MPERS. Some County employees were not informed about their eligibility to join the retirement system, which resulted in a hearing before the MPERS’s Board of Trustees. The Board implicitly or explicitly concluded that (1) MPERS had authority to adjudicate claims that some County employees were inadequately advised of their option to join MPERS at the time the employees were initially hired; (2) at the initial hiring of each employee, the County was obligated to adequately inform its employees of their eligibility to participate in the MPERS retirement plan; and (3) the County failed to meet that obligation with respect to certain employees. The Supreme Court vacated the judgment, holding that MPERS and the Board lacked statutory authority to decide disputes relating to information about opportunities to join MPERS. Remanded.View "Kennebec County v. Me. Pub. Employees Ret. Sys." on Justia Law

Since 1983, Michael Dee repeatedly and unsuccessfully challenged in state and federal courts the constitutionality of Maine marijuana prohibitions. In 2007, the superior court enjoined Dee from filing further lawsuits in Maine courts challenging the constitutionality of the State’s marijuana laws. Despite this injunction, Dee did not request the court’s permission to file this complaint for a judgment declaring that provisions in several Maine marijuana statutes were unconstitutional until almost one month after his complaint was docketed. The superior court dismissed Dee’s complaint with prejudice, finding that several Maine courts had already considered and rejected Dee’s arguments and that the suit was frivolous. The Supreme Court affirmed, holding that in light of the frivolous and duplicative nature of the suit and Dee’s failure to seek permission before commencing this action, the superior court did not abuse its discretion in granting the State’s motion to dismiss Dee’s petition with prejudice. View "Dee v. State" on Justia Law

After Harold Forest Snow died, Linda Moulton, as personal representative, filed a civil action against Susan Snow, alleging that one of the transfers identified in Harold’s codicil was an improvident transfer and a product of undue influence. During discovery, the parties’ attorneys announced that they had settled the case. Neither side, however, would agree to sign the other’s proposed settlement documents. Linda subsequently filed a motion to enforce the settlement agreement. The probate court granted Linda’s motion to enforce, finding that the record contained an “unequivocal stipulation by the parties’ attorneys that the matter was settled” and that the material terms of the agreement were clearly defined in the transcript. The Supreme Court affirmed, holding (1) there was ample evidence that the parties intended to enter into an enforceable settlement agreement and that the terms placed on the record reflected all of the material terms of the contract; and (2) the probate court did not abuse its discretion in granting the motion to enforce the settlement agreement without holding a trial or an evidentiary hearing. View "In re Estate of Snow" on Justia Law

The Oxford County Probate Court awarded guardianship of a child to the child’s paternal grandparents with the consent of the child’s father, finding that the grandparents met their burden of proving by clear and convincing evidence that the mother was an unfit parent and that it was in the child’s best interest to grant the guardianship. The mother appealed, arguing that the court erred in refusing to allow her to record the final hearing and that the court’s judgment was not supported by sufficient findings or evidence. The Supreme Court affirmed, holding (1) the court did not err in denying the mother’s request to record the final hearing at her own expense; and (2) the court’s findings were sufficient to support its judgment. View "In re Guardianship of Gabriel I.K. Johnson" on Justia Law

Zacharia was born to Mother and Father in 2009. Because Mother was transient at the time of Zacharia’s birth, Zacharia began living with Mother’s grandparents, who became temporary guardians of Zacharia. In 2011, Mother filed a petition to terminate the guardianship. After a hearing, the probate court (1) denied Mother’s petition, concluding that Mother was unfit because she was unable to meet Zacharia’s needs; and (2) rejected the guardian ad litem’s and Zacharia’s mental health therapist’s recommendations that transitional efforts be put into place, either upon termination of the guardianship or under a continued guardianship. The Supreme Court vacated the judgment, holding that the probate court (1) abused its discretion in declining to implement transitional arrangements; and (2) committed clear error in finding Mother unfit because that finding was premised upon the court’s erroneous denial of transitional arrangements. Remanded.View "In re Guardianship of Stevens" on Justia Law

After a jury trial, Defendant was found guilty of several sex offenses. The Supreme Court affirmed after clarifying the conduct the State was required to prove in order to prove the element of penetration, holding that the trial court did not err in (1) denying Defendant’s motion for a judgment of acquittal on the charge of unlawful sexual conduct, as the jury could have rationally made the finding that the State proved beyond a reasonable doubt every element of the offense; and (2) conducting voir dire, as no individual voir dire member disclosed a general bias against a defendant with mental illness.View "State v. Gladu" on Justia Law

After a jury trial, Defendant was found guilty of two counts of intentional or knowing murder. After Defendant’s convictions were affirmed on appeal, Defendant filed two consecutive motions seeking post-conviction DNA analysis of certain evidence. The superior court denied the motions, but the Supreme Court remanded for the superior court to make the required findings under the post-conviction DNA statute. On remand, the superior court denied Defendant’s motion a second time. The Supreme Court affirmed, holding that the trial court did not err in finding that Defendant failed to establish the chain of custody necessary to obtain an order for post-conviction DNA analysis.View "Cookson v. State" on Justia Law

Vera Boulier fell on the premises of Presque Isle Nursing Home (PINH), where Boulier was a resident. Boulier died from the injuries she sustained from the fall. The Estate of Boulier commenced an action against PINH for professional negligence in accordance with the Maine Health Security Act. A jury determined that PINH was not liable for Boulier’s death. The Estate appealed, arguing that the superior court erred in excluding evidence of remedial measures taken by PINH after Boulier’s fall and in rejecting the Estate’s proposed jury instruction on the theory of negligent communication. The Supreme Court affirmed, holding (1) the superior court did not abuse its discretion by excluding, pursuant to Me. R. Evid. 407, the evidence of PINH’s subsequent remedial measures; and (2) the superior court did not err in refusing to instruct the jury on the issue of negligent communication because the evidence did not generate an instruction on the issue.View "Estate of Boulier v. Presque Isle Nursing Home" on Justia Law

Santina Caruso was hired by The Jackson Laboratory as a veterinary technician to care for animals used in medical research. Caruso’s employment was terminated a few months later. Caruso subsequently filed a complaint alleging that the Laboratory had taken retaliatory action against her in violation of the Whistleblowers’ Protection Act after Caruso reported her concerns about the treatment of the animals. After a trial, the jury rendered a verdict in favor of the Laboratory. The Supreme Court affirmed, holding (1) the superior court erred in instructing the jury that it could find that Caruso had met her burden of proving causation only if it determined that Caruso’s whistleblowing activities made a “substantial” difference in determining whether Caruso was to be retained or terminated, but the error did not affect the verdict; and (2) the superior court did not err in failing to issue a corrective instruction or grant a new trial following certain statements made by the attorney for the Laboratory during closing arguments. View "Caruso v. The Jackson Lab." on Justia Law