Justia Maine Supreme Court Opinion Summaries

The case concerns an individual who engaged in a lengthy, high-speed police chase that began after a domestic dispute in Brunswick, Cumberland County. The individual left in his girlfriend’s car without permission and was soon pursued by police, first in Sagadahoc County and then back and forth between Sagadahoc and Cumberland Counties. Throughout the chase, he drove recklessly, endangered other drivers, and ultimately collided with a police cruiser, injuring an officer. The entire pursuit was captured on video and presented at trial.A criminal complaint was filed, and a Cumberland County grand jury indicted him on several charges, including eluding an officer and reckless conduct with a dangerous weapon. After it was discovered that some conduct occurred in Sagadahoc County, the State successfully moved to amend the indictment to include both counties. The trial court, sitting as the Cumberland County Unified Criminal Docket, denied the defendant’s motion for acquittal, and the jury found him guilty of eluding an officer and reckless conduct with a dangerous weapon. He was acquitted of some other charges, and this appeal followed.The Maine Supreme Judicial Court reviewed whether the Cumberland County grand jury had the authority to indict for conduct spanning both counties and whether the evidence supported the conviction for reckless conduct with a dangerous weapon. The Court held that both crimes were continuing offenses, committed in both counties, and could be indicted in either. The Court also held that the evidence was sufficient for the jury to find that the defendant used his vehicle as a dangerous weapon. The judgment of conviction was affirmed. View "State of Maine v. Coffill" on Justia Law

Keith Merchant was indicted on eight charges related to repeated sexual offenses against his niece, which occurred over several years beginning when she was twelve years old. The offenses included two counts of gross sexual assault, three counts of unlawful sexual contact, two counts of sexual abuse of a minor, and one count of violating a condition of release. Merchant pleaded guilty to all charges. At sentencing, the court considered testimony from law enforcement and unsworn statements from the victim and her family, noting the lengthy period of abuse and Merchant’s position of trust.The Somerset County Unified Criminal Docket accepted Merchant’s guilty pleas and conducted sentencing in accordance with the three-step analysis established in State v. Hewey and codified in Maine law. The court imposed twenty years’ imprisonment for the first gross sexual assault count and a consecutive ten-year sentence, plus ten years of supervised release, for the second gross sexual assault count. The remaining sentences were set to run concurrently with the first count. Merchant filed for, and was granted, leave to appeal his sentence by the Sentence Review Panel.The Maine Supreme Judicial Court reviewed the case and determined that the sentencing court erred by applying the same sentencing analysis to both primary gross sexual assault counts but issuing different sentences for each, without providing a logical or articulated basis for the disparity. The Court held that a separate, individualized sentencing analysis was required for each primary count that was to run consecutively. Consequently, the Court vacated Merchant’s sentence and remanded the case for resentencing in accordance with its opinion, specifying that no more severe sentence could be imposed on remand. View "State of Maine v. Merchant" on Justia Law

Law enforcement arrested an individual for operating under the influence after stopping him and bringing him to the police station. At the station, the officer explained the consequences of refusing a breath test, including administrative penalties and possible jail if the individual refused. After discussion and clarification that no additional charges would result from refusal, the individual agreed to take the breath test, although he initially stated he did not consent. The breath test was administered, and the individual was subsequently charged with criminal operating under the influence.The individual moved to suppress the breath test results in the Penobscot County Unified Criminal Docket, arguing that his consent to the test was not voluntary due to the officer’s statements and actions. The trial court denied the motion, citing Birchfield v. North Dakota, which held that warrantless breath tests incident to arrest do not require consent under the Fourth Amendment. After this ruling, the individual entered a conditional guilty plea, preserving his right to challenge the suppression ruling on appeal.The Supreme Judicial Court of Maine reviewed the case. The court held that, under Birchfield v. North Dakota, the Fourth Amendment allows warrantless breath tests as searches incident to arrest, and thus, the individual's consent was immaterial to the test’s admissibility. The court further concluded that the officer’s actions did not render the search unreasonable, as there were no false statements or arbitrary conduct, and the incentives provided by the officer were permissible. The court also held that the challenge must be analyzed under the Fourth Amendment rather than the Fourteenth Amendment’s Due Process Clause. Accordingly, the judgment was affirmed. View "State of Maine v. Davis" on Justia Law

New Cingular Wireless PCS, LLC applied to install six antennas on top of a water tower owned by the York Water District. The Town of York Planning Board approved the application. Two nearby property owners opposed the project, claiming it violated the local Wireless Communications Facilities Ordinance, specifically regarding fencing and setbacks from residential structures. They filed an administrative appeal with the Town of York Board of Appeals, which held public hearings. During the process, the Board asked New Cingular Wireless to provide a more accurate site plan showing distances to neighboring residences. After reviewing the updated information, the Board denied the neighbors’ appeal, stating it was satisfied with the information provided.The neighbors then sought judicial review in the York County Superior Court, arguing that the project did not comply with fencing and setback requirements. The Superior Court affirmed the Board’s decision. The neighbors appealed to the Maine Supreme Judicial Court, continuing to dispute whether the project met the ordinance’s requirements.The Maine Supreme Judicial Court concluded that the neighbors did not preserve their argument about fencing requirements, as this issue was not raised before the Board of Appeals and was therefore waived. However, the Court found that the setback issue had been properly preserved for review. The Court determined that the Board’s findings regarding setbacks were insufficient for appellate review, as the Board did not explain from where the setback was measured or whether the project met the ordinance’s requirements. The Court vacated the Superior Court’s judgment and remanded the matter to the Superior Court with instructions to remand it to the Board of Appeals for further factual findings and explanation regarding compliance with setback requirements. View "Drew v. Town of York" on Justia Law

A couple who had served as resource parents for a child involved in a protective custody proceeding filed a petition to adopt the child. Their petition was denied by the District Court, which instead granted adoption to another couple. The District Court based its decision on its determination that adoption by the other couple was in the child’s best interest. The resource parents appealed to the Maine Supreme Judicial Court, which affirmed the District Court’s decision, finding no clear error or abuse of discretion.Almost a year later, the resource parents filed several motions in the District Court, including a motion under Maine Rule of Civil Procedure 60(b) seeking relief from the adoption judgment. They argued that the adoptive parents had fraudulently misrepresented the nature of their relationship during the adoption proceedings and that new evidence supported their claim. The District Court denied these motions with prejudice, later providing a more detailed explanation. The court found the proffered evidence to be either discoverable at the time of trial, related to events occurring after judgment, or insufficient to prove fraud by clear and convincing evidence. The court also declined to hold an evidentiary hearing and ordered the resource parents to pay the adoptive parents’ attorney fees and costs.On appeal, the Maine Supreme Judicial Court reviewed the denial of the Rule 60(b) motion for abuse of discretion and the attorney fee award de novo. It concluded that the District Court did not abuse its discretion in denying relief from judgment or in declining to hold an evidentiary hearing, as the evidence was either not newly discovered or did not meet the heightened standard for fraud. However, the Supreme Judicial Court vacated the portion of the order awarding attorney fees, finding no basis for a sanction, and otherwise affirmed the judgment. View "Adoption by Kathleen C." on Justia Law

The case centers on a competitive bidding process conducted by the Maine Department of Health and Human Services (DHHS) for a contract to provide medical nonemergency transportation (NET) brokerage services in one of the state’s transit regions. Waldo Community Action Partners (Waldo CAP), the incumbent provider in Region 5 since 2014, submitted a proposal in response to the Request for Proposals (RFP). The RFP required bidders to detail their qualifications and provide three examples of relevant projects. Waldo CAP only completed details for one project, leaving the remaining two project sections blank except for the notation “NA.” After scoring, Waldo CAP did not receive the highest overall score; ModivCare Solutions, LLC, a vendor with extensive experience in other regions, was awarded the contract.Waldo CAP appealed the contract award to the Department of Administrative and Financial Services (DAFS) appeal committee, arguing that the process violated procurement laws and that the decision was arbitrary and capricious. The appeal committee affirmed DHHS’s decision, finding the point deduction for incomplete information justified and not arbitrary. Waldo CAP then sought judicial review in the Maine Superior Court, which also affirmed the committee’s decision.The Supreme Judicial Court of Maine reviewed the case, applying a deferential standard to the agency’s factual findings and statutory interpretations. The Court held that the “best-value bidder” under Maine law is determined strictly by the criteria and requirements set forth in the RFP, and that the agency acted within its discretion in scoring and did not act arbitrarily or capriciously. The Court affirmed the lower court’s judgment, upholding the award to ModivCare and lifting the stay on the contract award. View "Waldo Community Action Partners v. Department of Administrative and Financial Services" on Justia Law

The dispute centers on an injury suffered by Catherine Dudley at a property owned by Michel Kanyambo and Speciose Mahirwe, which was insured under a general liability policy issued by Hudson Specialty Insurance Company. The policy, procured through intermediaries, was in effect from September 14, 2017, to September 14, 2018. Before the expiration, a renewal quote was relayed from Hudson’s intermediary to Kanyambo via their insurance agent, but Kanyambo and Mahirwe never received a written quote nor communicated directly with Hudson or its intermediary. They took no steps to renew, and no written notice of nonrenewal was sent to them. Dudley was injured on the property nine days after the policy’s expiration and, after settling her claims against the owners, she initiated a statutory “reach-and-apply” action against Hudson.In the Androscoggin County Superior Court, both Dudley and Hudson sought summary judgment on whether the policy was effective at the time of the injury. The Superior Court granted summary judgment to Hudson, reasoning that the owners’ receipt of the renewal quote via their agent meant Hudson was not required to provide written notice of nonrenewal. The court found there was no material fact in dispute and held the policy was not in effect, barring Dudley’s claims against Hudson.The Maine Supreme Judicial Court reviewed the case de novo. It concluded that under the plain language of Maine’s statutes, an insurer must send a written notice of nonrenewal before a policy terminates at its expiration, regardless of whether the insurer offered to renew. The statutory definition of “nonrenewal” encompasses any termination at the expiration date, and failure to provide the required notice means the policy does not terminate. The Court vacated the summary judgment in favor of Hudson and remanded for further proceedings, holding that Hudson was obligated to send notice and its failure to do so meant coverage remained in effect. View "Dudley v. Hudson Specialty Insurance Company" on Justia Law

Eight residents of Boothbay and Boothbay Harbor challenged a school board’s refusal to put their petition for a new referendum before the voters. The underlying issue concerned a voter-approved bond to renovate local schools. After the bond passed, the residents submitted a petition containing two articles: one seeking to reconsider and repeal the prior vote, and another proposing a new, smaller bond for a different renovation project if the repeal succeeded. The school board rejected the petition, reasoning that it did not present a proper reconsideration question as required by statute and that the second article was unrelated to reconsidering the original referendum.The residents sought judicial review in the Lincoln County Superior Court under Rule 80B and also filed independent claims for a declaratory judgment and attorney fees, alleging a First Amendment violation. The Superior Court found that the petition was not a proper reconsideration petition because it included an additional article and that the independent claims were barred by the exclusivity principle. The residents then appealed.The Maine Supreme Judicial Court reviewed the case. It held that the statute governing reconsideration petitions imposes a ministerial duty on the board to initiate a referendum if the statutory requirements are met; thus, the Superior Court had jurisdiction. However, the Court found that the residents’ petition did not comply with the statutory requirements for a reconsideration petition, as it sought affirmative repeal and included a second, unrelated article, making it ineligible for submission to voters. The Court also affirmed the dismissal of the independent claims, holding there was no First Amendment violation. The judgment of the Superior Court was affirmed. View "Minerich v. Boothbay-Boothbay Harbor Community School District" on Justia Law

The case involves the conviction of a defendant for murder following the stabbing death of Kimberly Neptune, who was found in her apartment with 484 sharp force injuries. The defendant, Kailie Brackett, and a co-defendant, Donnell Dana, Jr., were indicted for intentional, knowing, or depraved indifference murder. The prosecution presented evidence including surveillance footage, testimony from witnesses about Brackett’s relationship with the victim and usage of the victim’s bank card, as well as forensic evidence from the crime scene. Notably, the prosecution relied on expert testimony comparing partial, sock-clad bloody footprints found at the scene to prints taken from Brackett in prison.The Washington County Unified Criminal Docket conducted the jury trial. Brackett objected to the admission of the forensic podiatry evidence, arguing it lacked scientific reliability. The trial court admitted the expert testimony over her objections, and the jury ultimately found Brackett guilty, but deadlocked as to Dana. Brackett was sentenced to fifty-five years in prison and appealed her conviction and sentence, challenging the sufficiency of the evidence, admission of the expert testimony, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court erred in admitting the forensic podiatry testimony comparing the partial, sock-clad footprints. The expert’s methodology lacked scientific reliability and was not sufficiently grounded in recognized standards, and the prosecutor’s closing arguments improperly characterized this evidence as definitive proof of Brackett’s presence at the scene. Because this error was likely to have affected the jury’s verdict, the Court vacated Brackett’s conviction and remanded for a new trial, holding that the State may retry Brackett but must exclude the challenged footprint comparison testimony. View "State of Maine v. Brackett" on Justia Law

Aaron Aldrich was convicted of two counts of intentional or knowing murder and possession of a firearm by a prohibited person. The evidence at trial showed that Aldrich went to a trailer in Poland, Maine, carrying a nine-millimeter rifle. He entered the trailer, shot both an adult and a teenager multiple times, and took a handgun and cash before leaving. Afterward, Aldrich told his friend he had killed the residents and instructed his girlfriend to dispose of evidence. The police later found forensic evidence linking Aldrich to the crime scene and recovered the murder weapon. He was apprehended in New Hampshire after fleeing in a stolen van.The Androscoggin County Unified Criminal Docket conducted a jury trial. Aldrich moved to suppress his post-arrest statements, claiming Miranda violations and improper questioning after requesting counsel; this motion was denied after an evidentiary hearing. The trial court made several evidentiary rulings, including admitting images of the victims, evidence of Aldrich’s theft and flight, testimony about his prior acts, and limiting cross-examination of witnesses. Aldrich testified, claiming self-defense. The jury found him guilty on all counts. He was sentenced to concurrent life terms for the murder convictions and five years for the firearm-possession count. Aldrich appealed both his convictions and sentences, arguing errors in suppression, evidentiary rulings, jury instructions, and sentencing analysis.The Maine Supreme Judicial Court reviewed all claims. The court held that the denial of the motion to suppress was correct because Aldrich was not subjected to custodial interrogation under Miranda. Most evidentiary rulings were proper; the few errors identified, including admission of hearsay and exclusion of certain defense evidence, were harmless and did not cumulatively deprive Aldrich of a fair trial. The jury instructions and sentencing analysis were found to be legally sound. The court affirmed the convictions and sentences. View "State of Maine v. Aldrich" on Justia Law