Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the superior court affirming the decision of the Belfast Zoning Board of Appeals (ZBA) to issue five permits to Nordic Aquafarms in connection with a proposed land-based salmon aquaculture preoject, holding that the ZBA erred as a matter of law in determining that Upstream Watch did not have standing to appeal.In dismissing the appeal, the ZBA determined that Upstream, a not-for-profit corporation dedicated to the restoration of Maine mid-coast rivers and streams, had not demonstrated a particularized injury sufficient to establish standing. The superior court dismissed Upstream's complaint for judicial review, ruling that the ZBA correctly found that Upstream had failed to exhaust its administrative remedies because it did not file a cognizable appeal with the ZBA. The Supreme Judicial Court vacated the judgment below and remanded the case, holding that, as a matter of law, the administrative record sufficiently demonstrated that Upstream had standing to appeal to the ZBA. View "Upstream Watch v. City of Belfast" on Justia Law

The Supreme Judicial Court vacated a portion of the summary judgment entered by the superior court in this action related to the estate of Patricia Spofford, the mother of Michael Zani and Peter Zani, holding that the Zanis' claim for declaratory judgment was not properly before the superior court.The Zanis brought this lawsuit seeking a declaratory judgment that Spofford lacked testamentary capacity when she executed her will and claiming that Kathryn Read committed fraud when she swore that Spofford had testamentary capacity at the time of the will's execution. The superior court entered partial summary judgment for Defendants. The Supreme Judicial Court vacated the order in part, holding (1) the claim for declaratory judgment was within the probate court's exclusive jurisdiction and was not properly before the superior court; and (2) the Zanis failed to establish a prima case for at least one element of their fraud claim. View "Zani v. Zani" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful trafficking in scheduled drugs and falsifying physical evidence, entered after a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized as the result of what Defendant argued was an unlawful arrest; (2) there was no obvious error in the admission of lay opinion testimony by law enforcement officers on certain matters; (3) the record evidence was sufficient to justify the trial court's giving a permissible-inference instruction; and (4) there was no error or abuse of discretion in the denial of Defendant's motion for new trial and for judgment of acquittal. View "State v. Abdullahi" on Justia Law

The Supreme Judicial Court dismissing Appellant's appeal from an order entered by the business and consumer docket dismissing two of three counts in Appellant's action against Flats Industrial, Inc. and three other Flats shareholders (collectively, Appellees), holding that Appellant's notice of appeal was untimely filed.Appellant, a Flats shareholder, filed this action claiming that Flats improperly failed to disclose records and breach of fiduciary duty. The court dismissed counts two and three of the second complaint and left count one as the only remaining claim for relief in the action. The parties later stipulated to the dismissal of count one. Appellant appealed, and Appellees moved to dismiss the appeal on the ground that Appellant's notice of appeal was not timely filed under Me. R. App. P. 2B(c)(1). The Supreme Judicial Court dismissed the appeal for lack of jurisdiction, holding that Appellant's appeal was filed after the deadline for appeal had expired. View "Fournier v. Flats Industrial, Inc." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of burglary, entered following a jury trial, holding that Defendant was not entitled to relief on his argument that he should be granted an acquittal.Defendant was indicted for various offenses, including burglary. During the jury trial, after the State rested, Defendant moved for a judgment of acquittal on the grounds that the State had not proven that he was not licensed or privileged to be in the house at issue because he was legally present on the premises as a tenant. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence in the record from which the jury could find that Defendant knew that he lacked the right to possess or occupy the premises the night of the offense; and (2) therefore, Defendant was not entitled to an acquittal. View "State v. Every" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing Key Bank National Association's complaint for foreclosure because the debtor or the debtor's estate was a necessary party and was not participating in the action, holding that neither the debtor nor the debtor's estate was a necessary party to the action.The debtor borrowed money from KeyBank and executed a promissory note for the loan. After the debtor died intestate the property at issue passed by operation of law to the debtor's wife as a surviving joint tenant. After the note went into default the wife conveyed the property to a third party. Thereafter, embank filed a complaint for foreclosure of the property against the debtor's wife and estate, as well as third party. The trial court dismissed the action without prejudice, holding that either the debtor or his estate must be named as a necessary party to the foreclosure action. The Supreme Judicial Court vacated the dismissal, holding that because a foreclosure does not include a claim for a deficiency judgment and is therefore solely in rem in nature any mortgagor or successor in interest is a necessary party but a deceased debtor is not. View "KeyBank National Ass'n v. Keniston" on Justia Law

The Supreme Judicial Court vacated in part the district court's amended divorce judgment in this action involving the modification of a divorce judgment, holding that the court erred in calculating child support by imputing an income to Mother that was higher than her actual income.The divorce judgment awarded Mother and Father shared parental rights and responsibilities as to their two children and allocated primary physical residence to Mother. Both parties later filed motions for contempt and Father moved to modify the judgment as to the children's residence, child support, and his rights of contact. The court granted Father's motion to modify and entered an amended divorce judgment. On appeal, Mother argued that the court erred in failing to find that her income was $37,287. The Supreme Judicial Court vacated the court's child support judgment and remanded the case, holding that the court's findings were insufficient to allow for effective appellate review because they did not indicate the court's basis for imputing income to Mother. View "Perreault v. Vallieres" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court entered upon a jury verdict in favor of Mainely Media, LLC on the tort claims brought by Norman Gaudette, a former Biddeford police officer, and his wife Joanne, holding that the trial court did not abuse its discretion in admitting certain testimony.The Gaudettes brought this action claiming defamation, false light, and loss of consortium alleging that Mainely Media had published incorrect information indicating that Norman had sexually abused minors years earlier while he was a police officer. The trial court entered judgment in favor of Mainely Media. On appeal, the Gaudettes argued that the trial court abused its discretion by refusing to strike a detective's testimony that an earlier investigation of Norman did not exonerate him. The Supreme Judicial Court affirmed, holding that the superior court did not abuse its discretion when it admitted the detective's testimony. View "Gaudette v. Mainely Media, LLC" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault but vacated his sentence of eight years' imprisonment to be followed by eight years of supervised release, holding that there was no error in Defendant's conviction but that the sentencing analysis used by the trial court resulted in obvious error that required correction.On appeal, Defendant argued that the trial court committed obvious error in its treatment of a note from the jurors during jury deliberations and because of prosecutorial error. The Supreme Judicial Court remanded the case for resentencing, holding (1) Defendant waived any objection to the court's response to the note; (2) there was no prosecutorial error or impropriety; and (3) the lower court had the authority to impose what was a lawful amended sentence, but the sentencing analysis employed by the court required that this Court vacate the sentence and remand for a de novo sentencing hearing. View "State v. Cummings" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court that reversed and modified the decision of the tax assessor of the Town of Vinalhaven denying Hurricane Island Foundation a local property tax exemption under Me. Rev. Stat. 36, 652(1)(B), holding that the Town's tax assessor correctly denied the tax exemption.In denying the Foundation's application, the Town's tax assessor concluded that the Foundation failed to meet the standard for a "literary and scientific" institution under the statute. The superior court twice remanded the case. For both the second and the third time, the assessor denied the tax exemption to the Foundation. The superior court modified the decision to designate the Foundation as tax exempt, concluding that there was an error of law in the assessor's decision. The Supreme Judicial Court vacated the judgment below and remanded for the court to enter a judgment declaring that the Foundation was not exempt, holding that the Foundation failed to show it was a "scientific" institution. View "Hurricane Island Foundation v. Town of Vinalhaven" on Justia Law