Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of one count of aggravated trafficking in scheduled drugs and two counts of criminal forfeiture, holding that the trial court did not err in denying either Defendant's motion to suppress or his motion for discovery.On appeal, Defendant argued that the trial court erred when it denied his motion to suppress and his request for additional discovery relating to the State's cooperating defendant. The Supreme Judicial Court affirmed, holding (1) law enforcement agents had probable cause to support their stop of Defendant, and therefore, the trial court did not err when it denied Defendant's motion to suppress; and (2) the trial court did not abuse its discretion in denying Defendant's discovery motion. View "State v. Lepenn" on Justia Law

The Supreme Judicial Court vacated the series of consecutive sentences imposed by the trial court upon Appellant's guilty pleas to ten counts of aggravated attempted murder and other crimes, holding that the trial court did not make the factual findings required for the imposition of consecutive sentences.Appellant pleaded guilty to ten counts of aggravated attempted murder, one count of robbery, one count of failure to stop, and one count of theft. The trial court sentenced Appellant to an aggregate of 225 years of incarceration, with no less than thirty years to be served. The State later agreed that the sentence imposed was unlawful. The Supreme Judicial Court vacated the sentences, holding that the court imposed consecutive sentences without making the required findings and providing the required explanation for each conviction, in violation of Me. Rev. Stat. 17-A, 1608(1). View "State v. Murray-Burns" on Justia Law

The Supreme Judicial Court answered a certified question as follows: no warranty is implied by the use of the term "Warranty Deed" to describe an instrument which "grants...real property with the buildings and improvements thereon...being the same premises conveyed to GRANTOR" by prior deed.The United States District Court for the Western District of Washington certified to the Supreme Judicial Court the question of whether, under Maine law, any warranty was implied by use of the term "Warranty Deed" to describe the instrument at issue and, if so, which warranty or warranties were implied. The Supreme Judicial Court answered the question in the negative, concluding that no warranty was implied by the use of the term "Warranty Deed" to describe an instrument that "grants...real property with the buildings and improvements thereon...being the same premises conveyed to GRANTOR" by prior deed. View "Kneizys v. Federal Deposit Insurance Corp." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for aggravated trafficking of scheduled drugs and unlawful possession of scheduled drugs, 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 commit clear error when it allowed ta confidential informant (CI) to testify regarding the manner in which he had previously met with Defendant to obtain drugs; (2) any prosecutorial error during closing argument about the role of CIs in society did not affect Defendant's substantial rights; and (3) there was no error in the jury instructions given during the proceedings below. View "State v. Osborn" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder but vacated his sentence, holding that a criminal defendant's decision to exercise his constitutional right to a trial by jury may not be considered at sentencing.After a seven-day trial at which Defendant did not testify, the jury returned a verdict of guilty to murder. After a sentencing hearing, the court found that there were no mitigating circumstances and imposed a thirty-two-year sentence. The Supreme Judicial Court vacated Defendant's sentence, holding that the trial court (1) did not err when it denied Defendant's request to provide him with access to the grand jury transcript; but (2) abused its discretion by referencing Defendant's demand for a jury trial in determining the genuineness of Defendant's claim of personal reform and contrition. View "State v. Moore" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court adopting the final order of the family law magistrate ordering Mother's divorce from Father, awarding sole parental rights and responsibilities of the parties' child to Father, and distributing the parties' property, holding that the record lacked competent evidence to support the district court's findings.Mother, acting pro se, timely filed an objection to the final order of the magistrate, but the court denied the motion and adopted the magistrate's judgment. Mother then filed for relief from judgment, to set aside the default judgment, for a new trial, and for amended or additional factual findings. The motions were denied. The Supreme Judicial Court remanded the case, holding (1) when asserting that a magistrate's judgment lacks sufficient fact-finding, the objecting party should make her claim in a Mont. R. Civ. P. 118(a) objection, not a Mont. R. Civ. P. 52 motion after the district court has reviewed the Rule 118(a) objection; and (2) remand was necessary in this case because the existing record did not support the judgment. View "Daniel v. McCoy" on Justia Law

The Supreme Judicial Court affirmed the judgment convicting Defendant of two counts of gross sexual assault, holding that the trial court did not err in determining that Defendant was an "other official" under Me. Rev. Stat. 17-A 253(2)(F).Defendant was a fifty-seven-year old driving school owner who taught driver's education courses at a public high school in Skowhegan. On two occasions, Defendant picked up the victim at school in the vehicle that he used to teach students to drive, drove her to a motel, and engaged in a "sexual act" with the victim. The State charged Defendant with two counts of gross sexual assault under section 253(2)(F), under which a person is guilty if he engages in a sexual act with a student and the actor is a "teacher, employee or other official having instructional, supervisory or disciplinary authority over the student." The trial court concluded that Defendant was an "other official" of the high school and convicted him of both charges. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support the lower court's findings. View "State v. Marquis" on Justia Law

The Supreme Judicial Court vacated the judgment entered by the superior court determining ownership and land use rights in intertidal land bordering Penobscot Bay, holding that the disputed land belonged to Jeffrey Mabee and Judith Grace under the plain language of the relevant deeds.Nordic Aquafarms Inc. negotiated an agreement with Richard and Janet Eckrote to bury industrial pipes in the intertidal land located between the Eckrotes' upland property and Penobscot Bay. During the ensuing trial, the City bought the Eckrotes' property and was granted intervenor status. Mabee and Grace jointly owned property near the Eckrotes' property and claimed that they owned not only the intertidal land abutting their own upland property but also the intertidal land abutting the upland properties of the Eckrotes. The superior court concluded that Mabee and Grace failed to establish title to the intertidal land abutting the Eckrotes' upland properties. The Supreme Judicial Court vacated the judgment, holding (1) the governing deed conveying land did not include the intertidal land that was eventually conveyed to Mabee and Grace; and (2) Mabee and Grace held an enforceable servitude over the Eckrotes' upland. View "Mabee v. Nordic Aquafarms, Inc." on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court dismissing Plaintiff's claims for abuse of process and wrongful use of civil proceedings, holding that the trial court erred in dismissing Plaintiff's claim for wrongful use of civil proceedings.Plaintiff sued three New York-based dentists and their dental practice (collectively, Defendants) asserting claims for abuse of process, wrongful use of civil proceedings, and punitive damages. Defendants filed a motion to dismiss for failure to state a claim pursuant to Me. R. Civ. P. 12(b)(6). The trial court granted the motion. The Supreme Judicial Court reversed in part, holding that Plaintiff's complaint stated a claim for wrongful use of civil proceedings but not for abuse of process. View "Leighton v. Lowenberg" on Justia Law

The Supreme Judicial Court vacated the order of the superior court granting Stephen Witham's motion for an extension of time to file his notice of appeal and dismissed Witham's appeal as untimely, holding that Witham's notice of appeal was untimely.At issue was the decision of the Board of Trustees of the Maine Criminal Justice Academy adopting a hearing officer's recommended decision to revoke Witham's certificate of eligibility as a law enforcement officer. The superior court affirmed the decision. Witham filed a notice of appeal together with a motion for an extension of time to file a notice of appeal. The court granted Witham's motion for an extension. The Supreme Judicial Court vacated the order and dismissed Witham's appeal as untimely, holding that the lower court erred in granting Witham's motion for an extension under the circumstances. View "Witham v. Bd. of Trustees of Me. Criminal Justice Academy" on Justia Law