Justia Maine Supreme Court Opinion Summaries

Jarae Lipscombe was convicted by a jury of hindering apprehension or prosecution (Class B) for actions taken to delay or prevent the apprehension of his brother, who was later charged with homicide in Waterville. Lipscombe provided false information to the police and assisted his brother in avoiding capture. Five months after his conviction, Lipscombe moved for a new trial, arguing that his brother's acquittal of murder would likely lead to a different outcome in his own case. The trial court denied the motion, and Lipscombe appealed.The Kennebec County trial court held a three-day jury trial where Lipscombe's defense focused on his lack of knowledge regarding his brother's involvement in the homicide. The State presented evidence showing that Lipscombe gave a false description to the police, knew the police were seeking his brother, and made arrangements for his brother to stay at a friend's house. Additionally, Lipscombe confessed to witnessing his brother shoot the victim and offered money to retrieve the weapon. After the jury found Lipscombe guilty, he appealed the judgment, which was affirmed by the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed Lipscombe's appeal of the trial court's denial of his motion for a new trial. The court held that the acquittal of Lipscombe's brother was irrelevant to Lipscombe's conviction. The court explained that the statute defining hindering apprehension or prosecution does not require proof of the brother's guilt but rather that Lipscombe knew of his brother's conduct that could render him liable to a charge of murder. The court affirmed the judgment, concluding that the brother's acquittal did not change the factual circumstances of the conduct Lipscombe witnessed. View "State of Maine v. Lipscombe" on Justia Law

Newfield Sand, a Maine corporation engaged in mineral extraction, owns a nearly three-hundred-acre parcel in the Town of Newfield. In 1994, the Planning Board granted a permit to the previous owner for a five-acre gravel-extraction operation with specific conditions on hours of operation and truck trips. Newfield Sand acquired the property in 1998 and sought to expand its operations. In May 2022, Newfield Sand applied for a conditional use permit to operate on thirty acres of open pit at a time and extract minerals from about eighty-five acres. The Planning Board approved the application in November 2023, subject to conditions, including provisions allowing the Board to reevaluate the hours of operation and truck trip limits.The Business and Consumer Docket affirmed the Planning Board’s decision. Newfield Sand appealed, arguing that the Planning Board lacked the authority to retain jurisdiction and modify permit conditions post-approval. The Town contended that the Board’s authority to impose such conditions was implied.The Maine Supreme Judicial Court reviewed the case and concluded that the ordinance did not explicitly or implicitly authorize the Planning Board to modify or revoke a permit after issuance or retain jurisdiction over it. The Court found that the conditions allowing reevaluation of hours of operation and truck trips were outside the Board’s authority and did not clearly define compliance requirements. Consequently, the Court vacated the lower court’s judgment and remanded the matter to the Planning Board for further consideration of Newfield Sand’s application for a conditional use permit. View "Newfield Sand v. Town of Newfield" on Justia Law

Sokunthim Nou appeals from a divorce judgment entered by the District Court in which the court allocated property between her and Rotanak Huot and awarded shared parental rights and responsibilities and shared residency of their children. Sokunthim challenges the court’s property determinations on multiple grounds, but does not contest the custody determination. The court found that all the parties’ assets were marital because they were acquired during the marriage and through significant effort by both parties. The court allocated just over half of the net value of the parties’ properties to Sokunthim and the remainder to Rotanak. The court also found Sokunthim’s income to be $435,598, based largely on Rotanak’s testimony about Punky’s LLC’s daily sales.The District Court held a trial with both parties represented by counsel and interpreters present. The court heard testimony from the parties, a real estate broker, Sokunthim’s accountant, and her father. The court entered a comprehensive divorce judgment, determining that all the parties’ assets were marital and allocating them accordingly. The court’s judgment awarded Panyah LLC to Rotanak and implicitly awarded Punky’s LLC to Sokunthim. Sokunthim filed motions for additional findings of fact and conclusions of law and for a new trial, which the court denied.The Maine Supreme Judicial Court reviewed the case and found that the trial court’s determination of Sokunthim’s income was unsupported by the evidence. The court’s finding as to her income may have influenced other financial aspects of the judgment. Therefore, the Supreme Judicial Court vacated the division of property and child support award and remanded for further proceedings. The judgment was affirmed in all other respects. View "Nou v. Huot" on Justia Law

Marc A. Lesperance was found with his dog off-leash in Baxter Woods, Portland, despite a city ordinance requiring dogs to be leashed from April 1 to July 31. A park ranger informed Lesperance of the rule, but Lesperance refused to comply. The ranger, after consulting with a colleague, issued a summons and complaint. The District Court (Portland) fined Lesperance $500, noting it was not his first violation of the ordinance.Lesperance appealed, arguing that the park ranger was not authorized to issue the summons and complaint. He also claimed the city ordinance was preempted by state law and unconstitutionally vague. The court found these arguments without merit, stating the ordinance was clear and not preempted by state law.The Maine Supreme Judicial Court reviewed the case. The court considered whether the park ranger, appointed as a constable, needed to meet specific training requirements to enforce the ordinance. The Attorney General, representing the Maine Criminal Justice Academy, suggested that constables might require less rigorous training than law enforcement officers. The court applied the "de facto officer" doctrine, concluding that Lesperance could not challenge the ranger's authority based on potential training deficiencies. The court affirmed the judgment, validating the ranger's actions as those of a de facto officer. View "City of Portland v. Lesperance" on Justia Law

Kiril Lozanov and Capital City Renewables, Inc. (CCR) appealed a Superior Court decision granting summary judgment in favor of Lily B. Piel. Lozanov and CCR alleged that Piel, a former employee, accessed and disclosed Lozanov’s personal emails without authorization, which included confidential information about a wind project unrelated to CCR. Lozanov claimed that Piel’s actions led to increased child support obligations and health issues due to stress from related litigation.The Superior Court dismissed CCR’s claim for intrusion upon seclusion, as the company did not have a right to privacy in Lozanov’s emails. Lozanov’s claim for intentional infliction of emotional distress was also dismissed, as the court found Piel’s conduct was not outrageous enough to warrant such a claim. The court allowed Lozanov’s intrusion upon seclusion claim to proceed but ultimately granted summary judgment for Piel on all counts, finding no evidence that Piel’s actions caused the alleged damages.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Superior Court’s decision. The court found no evidence that Piel breached any duty owed to CCR or that her actions caused the damages claimed by Lozanov and CCR. The court also concluded that CCR's and Lozanov’s damages were too remote and speculative to support their claims. Additionally, the court noted that public policy considerations barred recovery, as Lozanov’s attempt to hide assets in a child support proceeding was contrary to the best interests of the child and public policy. View "Capital City Renewables, Inc. v. Piel" on Justia Law

Patrick Bolduc and Savannah Getchius were married in 2011 and have three minor children. Bolduc filed for divorce in 2021. After two unsuccessful mediations, a final divorce hearing was held in June 2023. The District Court awarded Bolduc sole parental rights and responsibilities and divided the marital property. The court found that Bolduc's property, purchased before the marriage, appreciated in value during the marriage due to both market forces and marital improvements.The District Court determined that the entire appreciation of the property during the marriage was marital property. The court also ordered Getchius to pay $325 weekly in child support and $10,000 of Bolduc's attorney fees. Bolduc filed motions for further findings and to alter the judgment, which the court mostly denied, except for making limited additional findings.The Maine Supreme Judicial Court reviewed the case. It affirmed the lower court's decision on the classification of the real property, agreeing that Bolduc did not meet his burden to prove that the appreciation was solely due to market forces. The court also upheld the child support order, finding no error in the calculation or the decision not to order Getchius to pay $1,800 for uninsured medical expenses. However, the court found that the attorney fee award was based on an affidavit that included fees unrelated to the divorce proceedings. The court vacated the attorney fee award and remanded for recalculation of the fees properly subject to an award in the divorce action. View "Bolduc v. Getchius" on Justia Law

Matthew W. Pendleton was convicted of manslaughter after a jury trial. Pendleton and the victim, Kevin Curit, were childhood friends, and Curit had moved into Pendleton's home. On January 5, 2023, Pendleton bought alcohol, and later that night, he sent text messages to his daughter, including photos of Curit lying unconscious and statements about injuring his hands. The next morning, Pendleton texted his estranged wife that Curit was dead and later called 9-1-1. The police found Curit dead in a camper with multiple injuries, and the medical examiner concluded that Curit died of strangulation by ligature.The Waldo County trial court admitted screenshots of Pendleton's text messages and his daughter's testimony about his alcohol use and their family dynamic. The court also allowed a jailhouse informant to testify but struck the testimony and instructed the jury to disregard it after the informant mentioned meeting Pendleton in jail. Pendleton was found guilty of manslaughter and sentenced to twenty years in prison, with all but fourteen years suspended, followed by four years of probation.Pendleton appealed to the Maine Supreme Judicial Court, challenging the admission of the text messages and his daughter's testimony, the handling of the jailhouse informant's testimony, and the court's refusal to consider a juror's affidavit during sentencing. The court affirmed the conviction and sentence, finding no abuse of discretion in the trial court's rulings. The court held that the text messages were relevant and not unfairly prejudicial, the daughter's testimony was admissible, the curative measures for the informant's testimony were sufficient, and the juror's affidavit was properly excluded from sentencing considerations. View "State of Maine v. Pendleton" on Justia Law

Moosehead Mountain Resort, Inc., and OFLC, Inc. (collectively Moosehead) filed a civil action against Carmen Rebozo Foundation, Inc., alleging breach of contract, unjust enrichment, and breach of good faith and fair dealing. The dispute arose from a promissory note for $6,350,000 executed by Moosehead and assigned to the Foundation, which allegedly misrepresented the amount due, impacting Moosehead's efforts to sell a ski resort.The Superior Court (Piscataquis County) denied Moosehead’s motion for summary judgment and the Foundation’s motion for relief under Maine Rule of Civil Procedure 56(f), ordering a judicial settlement conference. The parties reached a settlement, agreeing to dismiss the case with prejudice. However, no docket entries were filed within the court's deadline, leading to the case's dismissal with prejudice. Moosehead then filed a motion for reconsideration and to vacate the settlement agreement, which the court denied. The Foundation's motion to enforce the settlement agreement was granted.The Maine Supreme Judicial Court reviewed the case. It affirmed the denial of Moosehead’s motion for reconsideration, finding no abuse of discretion. However, it vacated the judgment enforcing the settlement agreement, concluding that the court lacked jurisdiction to enforce it after the case was dismissed with prejudice. The court noted that the parties failed to take necessary steps to preserve the court's jurisdiction over the settlement agreement before the dismissal. The case was remanded for an order dismissing the motion to enforce the settlement agreement for want of jurisdiction. View "Moosehead Mountain Resort, Inc. v. Carmen Rebozo Foundation, Inc." on Justia Law

Kateryna A. Bagrii sought to establish herself as a de facto parent of two children whose biological parents are John P. Campbell and Jie Chen. Bagrii claimed she had acted as a parent to the children since 2014, after Campbell brought them from China to Ukraine without Chen's consent. Bagrii and Campbell later married and moved to the United States with the children. Bagrii argued that she had taken on full parental responsibilities and that her relationship with the children was in their best interests.The District Court (Newport, Ociepka, J.) dismissed Bagrii’s complaint for lack of standing, finding that although she proved most elements required for de facto parentage, she failed to demonstrate that Chen had fostered or supported her relationship with the children or accepted her parental role. The court noted that Chen had not consented to the children's removal from China and had not known their whereabouts for several years.The Maine Supreme Judicial Court reviewed the case and affirmed the District Court's judgment. The court held that under the Maine Parentage Act, a person seeking de facto parent status must prove that all legal parents who appear and object to the petition have fostered or supported the relationship. The court found that Chen had not implicitly or explicitly consented to Bagrii’s parental role. The court also rejected Bagrii’s request to exercise parens patriae authority, stating that due process principles require proof of consent from all legal parents. Thus, the judgment dismissing Bagrii’s complaint for lack of standing was affirmed. View "Bagrii v. Campbell" on Justia Law

Fair Friend Enterprise Co., Ltd., a Taiwan-based company and majority shareholder of CNC Systems, Inc., sought access to CNC's corporate books and records under Maine law. Fair Friend alleged that CNC had failed to pay for goods worth approximately $4 million and had unilaterally demoted its CEO without approval. Fair Friend made a written demand for access to CNC's records, which CNC ignored, leading Fair Friend to file a complaint in the Maine Superior Court.The Maine Superior Court ordered CNC to produce the requested records and denied CNC's motion to stay the proceedings due to related litigation in California. The court found that Fair Friend had a proper purpose for requesting the records and that CNC's actions warranted concern. CNC continued to delay compliance, prompting further court orders to enforce the production of records and awarding attorney fees to Fair Friend.The Maine Supreme Judicial Court reviewed the case. CNC's appeal of the denial of the motion to stay was dismissed as moot because CNC eventually produced the requested records. The court affirmed the award of attorney fees, concluding that CNC had not acted in good faith and had no reasonable basis for doubting Fair Friend's right to inspect the records. The court found that CNC's resistance to producing the documents and filing of serial motions to delay justified the award of attorney fees. The case was remanded for dismissal of all pending motions and entry of final judgment. View "Fair Friend Enterprise Co., Ltd. v. CNC Systems, Inc." on Justia Law