Justia Maine Supreme Court Opinion Summaries

The case involves a dispute between two condominium associations, Longview Hotel Condominium Association (Longview) and Pearl Inn Condominium Association (Pearl), over a strip of land used for parking. Longview owns a beachfront property with six units and an adjacent parking lot, while Pearl owns a nearby property with eight units. The contested area is a rectangular strip of land adjacent to Pearl's building, which has been used by Pearl's residents for parking for decades. Longview claims that Pearl's use of this land constitutes trespass, while Pearl asserts it has acquired the land through adverse possession.The Superior Court (York County) ruled in favor of Pearl, finding that Pearl had acquired the strip of land by adverse possession. The court determined that Pearl's use of the land was continuous, open, and notorious for the required twenty-year period. The court also directed Pearl to submit a proposed judgment with a specific metes-and-bounds description of the adversely possessed area. Longview appealed, arguing that the court erred in its determination of continuous use and in setting the boundaries of the land acquired by adverse possession.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's finding that Pearl had satisfied the elements of adverse possession, including continuous use. The court found sufficient evidence that Pearl's residents had used the disputed area for parking consistently over the years. However, the Supreme Judicial Court vacated the portion of the judgment concerning the boundaries of the adversely possessed land. The court found that the description provided by Pearl included areas not supported by evidence of actual or continuous use. The case was remanded for a revised metes-and-bounds description that accurately reflects the area used by Pearl's residents. View "Longview Hotel Condominium Association v. Pearl Inn" on Justia Law

In May 2021, Ronald A. Harding lived with his girlfriend, her three children, and their infant son. On May 31, 2021, Harding was holding the infant when the child became unresponsive and later died. Medical examinations revealed that the infant suffered from a fatal brain injury consistent with non-accidental trauma, specifically shaken impact syndrome. Harding was arrested on June 4, 2021, and charged with manslaughter. He was later indicted by a grand jury on one count of manslaughter.The trial took place over four days in early 2023. The State presented testimony from medical professionals and experts who treated the infant and performed the autopsy. The defense argued that the death could have been caused by COVID-19 or an earlier injury, presenting testimony from their own expert, Dr. Jane Turner. The jury found Harding guilty of manslaughter. Harding's motions for a judgment of acquittal and a judgment notwithstanding the verdict were denied by the trial court.The Maine Supreme Judicial Court reviewed the case. Harding argued that the evidence was insufficient to support the conviction and that the State committed prosecutorial error during its closing argument. The court held that the evidence was sufficient for a rational jury to find Harding guilty beyond a reasonable doubt. The court also found that Harding had waived his prosecutorial error argument by withdrawing his request for a curative instruction during the trial. Consequently, the court affirmed the judgment of conviction. View "State of Maine v. Harding" on Justia Law

Geoffrey S. Stiff and Carolyn B. Stiff own a lot on Long Pond in Belgrade, Maine. Their neighbors, Stephen C. Jones and Jody C. Jones, own an adjacent 1.23-acre lot within the limited residential district of the Belgrade shoreland zone. The Joneses' lot is legally non-conforming and already contains a non-conforming house and a shed. In 2017, the Joneses sought a permit to build a garage with a laundry room and playroom. However, they constructed a two-story structure with three bedrooms, two bathrooms, a laundry room, and a playroom with kitchen appliances, which was not in accordance with the permit.The Stiffs objected to the new structure, leading the Joneses to apply for an after-the-fact permit from the Town of Belgrade Planning Board. The Planning Board approved the permit with the condition that kitchen appliances be removed. The Stiffs appealed to the Board of Appeals (BOA), which remanded the matter due to a lack of findings of fact or conclusions of law. On remand, the Planning Board again approved the permit, finding the new structure to be an accessory structure. The Stiffs appealed to the BOA again, and after the BOA denied their appeal, they filed a complaint in the Superior Court, which also denied their appeal.The Maine Supreme Judicial Court reviewed the case and found that the Planning Board had misconstrued the Belgrade Shoreland Zoning Ordinance (SZO). The court held that the new structure was not an accessory structure as defined by the SZO because it was not incidental and subordinate to the existing house. The court vacated the judgment and remanded the case to the Superior Court with instructions to remand to the BOA, which would then remand to the Planning Board for further proceedings consistent with the opinion. View "Stiff v. Town of Belgrade" on Justia Law

In May 2021, Ronald A. Harding lived with his girlfriend, her three children, and their infant son. On May 31, 2021, Harding was holding the infant when the child became unresponsive and later died. Medical examinations revealed that the infant suffered from a fatal brain injury consistent with non-accidental trauma, specifically shaken impact syndrome. Harding was arrested on June 4, 2021, and charged with manslaughter. A grand jury indicted him on June 30, 2021. During the trial, the State presented evidence from medical professionals and experts who testified that the infant's injuries were caused by traumatic head injury while in Harding's care.The Penobscot County Unified Criminal Docket oversaw the initial trial. Harding moved for a judgment of acquittal after the State rested its case and renewed the motion after the close of evidence, but the trial court denied both motions. The jury found Harding guilty of manslaughter, and the court entered a judgment of conviction on September 19, 2023. Harding was sentenced to fifteen years, with all but eight and a half years suspended, and six years of probation. Harding appealed, arguing insufficient evidence and prosecutorial error during closing arguments.The Maine Supreme Judicial Court reviewed the case. The court held that sufficient evidence supported the manslaughter conviction, noting that the jury was entitled to resolve conflicting evidence and determine witness credibility. The court also found that Harding waived his prosecutorial error argument by withdrawing his request for a curative instruction and not moving for a mistrial. Consequently, the court affirmed the judgment of conviction. View "In re Children of Destiny H." on Justia Law

The case involves a property dispute in the Holiday Beach neighborhood of Owls Head, Maine, between John M. Carter and Christine C. Carter (the Carters) and their neighbors, Michael A. Voncannon and N. Kermit Voncannon (the Voncannons), and Zachary Rogers and Kathryn Rogers as Trustees of the Nancy C. Rogers Irrevocable Trust (the Rogerses). The dispute centers on the ownership and use of two "paper streets"—Austin Avenue and the Reserved Way—that transect their properties.The Business and Consumer Docket (Murphy, J.) held a bench trial and found that the Carters had superior title to Austin Avenue, while the Voncannons and Rogerses had acquired title to the Reserved Way through adverse possession. The court determined that the Carters' deed conveyed the Reserved Way to them, but the Voncannons and Rogerses had used the Reserved Way openly, notoriously, and exclusively for over twenty years, thus meeting the requirements for adverse possession. The court also found that the Reserved Way terminates at Holiday Beach Road and does not extend to the high-water mark of Owls Head Harbor.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's judgment. The Court held that the Carters had full record title to Austin Avenue and that the Voncannons and Rogerses' activities on Austin Avenue constituted trespass. The Court also upheld the finding that the Reserved Way terminates at Holiday Beach Road, not the high-water mark. Additionally, the Court agreed that the Voncannons and Rogerses had acquired title to their respective halves of the Reserved Way through adverse possession, as their use of the land was actual, open, visible, notorious, hostile, under a claim of right, continuous, and exclusive for the statutory period. The Court found no clear error in the trial court's factual determinations and legal conclusions. View "Carter v. Voncannon" on Justia Law

Rebecca Adeyanju, a White woman, was employed by Foot and Ankle Associates of Maine, P.A. as a medical assistant and radiology technician since 2012. In 2018, she married a Black man from Nigeria. In August 2019, Adeyanju missed three consecutive workdays to assist her husband, who was being sought by ICE agents. She informed her employer of her absences via text messages. Upon returning to work, she was terminated for "job abandonment" due to her three-day absence.The Superior Court (Cumberland County) granted summary judgment in favor of Foot and Ankle Associates, concluding that Adeyanju failed to show sufficient evidence that her termination was motivated by discriminatory animus or that the stated reason for her termination was pretextual. Adeyanju appealed the decision.The Maine Supreme Judicial Court reviewed the case de novo. The court found that the summary judgment record, viewed in the light most favorable to Adeyanju, revealed genuine issues of material fact. These included inconsistencies in the employer's enforcement of its attendance policy, differential treatment of employees with similar absences, and potential racial animus linked to the involvement of ICE. The court concluded that these issues warranted a trial to determine whether the termination was indeed motivated by discriminatory animus or if the employer's stated reason was pretextual.The Maine Supreme Judicial Court vacated the summary judgment and remanded the case for trial, allowing Adeyanju to present her claims of employment discrimination under Title VII and 42 U.S.C. § 1981. View "Adeyanju v. Foot and Ankle Associates of Maine, P.A." on Justia Law

Gregory R. Flagg filed for divorce from Shauna K. Bartlett in 2012, resulting in a settlement agreement that included shared parental rights and responsibilities, with a child support order requiring Flagg to pay $81 weekly. In 2021, Bartlett moved to modify the child support order, and Flagg cross-moved to modify the divorce judgment and child support order, citing substantial changes in circumstances. The District Court initially granted Flagg's motion, determining that Bartlett did not provide substantially equal care and awarded primary residence to Flagg without child support. Bartlett then filed a motion to alter or amend the judgment.The District Court later amended its judgment, granting Bartlett's motion to modify child support and denying Flagg's cross-motion. The court found that although Flagg provided more care, the level of care had not significantly changed since the original agreement. The court concluded that the care provided by both parents was substantially equal and modified Flagg's child support obligation to $185 weekly. Flagg appealed, arguing that the court erred in determining that the parties provided substantially equal care.The Maine Supreme Judicial Court reviewed the case and found that the District Court had abused its discretion by failing to properly assess whether the parties provided substantially equal care for the purpose of determining child support. The Supreme Judicial Court vacated the amended judgment, the amended child support order, and the order denying Flagg's motions for findings of fact and conclusions of law. The case was remanded for further proceedings to determine whether the parties are providing substantially equal care and to make consistent findings of fact and conclusions of law. View "Flagg v. Bartlett" on Justia Law

In this case, Randall C. Belyea was the sole shareholder and president of Belyea Enterprises, Inc. (BEI), which had a contract with FedEx. Due to a misdemeanor charge, FedEx refused to renew the contract with Belyea, leading him to transfer his interest in BEI to his fiancée, Heather A. Campbell, under the understanding that she would be the owner in name only while he continued to run the business. However, in 2018, Campbell terminated Belyea's employment and restricted his access to BEI's bank accounts.The Superior Court (Aroostook County) initially granted Campbell’s motion for judgment as a matter of law on Belyea’s conversion claim and later entered judgment as a matter of law in favor of Campbell on Belyea’s breach of contract claim, despite a jury verdict in Belyea’s favor. The court found that there was insufficient evidence of an enforceable contract between Belyea and Campbell, as the terms were too vague and indefinite.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's decisions. The court held that the terms of the alleged contract between Belyea and Campbell were not sufficiently definite to form an enforceable contract. The terms did not clearly define the roles and obligations of each party, the duration of the contract, or the details regarding a possible reconveyance of BEI to Belyea. Consequently, the court also upheld the judgment in favor of Campbell on the conversion claim, as Belyea did not have a legal interest in BEI in 2018. View "Belyea v. Campbell" on Justia Law

A group of plaintiffs, including William Clardy, Michelle Tucker, two state representatives, and a nonprofit corporation, filed a lawsuit against Maine's Senate President, Speaker of the House, and Governor. They sought to invalidate a special legislative session called by the Governor, arguing it was unconstitutional. The plaintiffs claimed the session was based on a "contrived" extraordinary occasion and that the legislative leaders ceded power to the executive branch. They sought declarations that the session and the legislation passed during it were void.The Kennebec County Superior Court dismissed the complaint for failure to state a claim. The court did not decide on the plaintiffs' standing but ruled that the Governor's determination of an extraordinary occasion to convene the Legislature was not subject to judicial review. Additionally, the court found that the legislative leaders were immune from suit for their actions. The plaintiffs appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the dismissal, but on different grounds. The court held that the plaintiffs lacked standing to bring the suit. The court found that the individual plaintiffs, as citizens and taxpayers, did not demonstrate a particularized injury distinct from the general public. The state representatives failed to show a concrete injury arising from the Governor's proclamation or the convening of the special session. Lastly, the nonprofit corporation lacked standing because its members did not have standing to sue individually. The court concluded that no plaintiff had suffered an injury sufficient to confer standing, thus affirming the lower court's dismissal of the case. View "Clardy v. Jackson" on Justia Law

The Industrial Energy Consumer Group (IECG) appealed an order from the Public Utilities Commission (PUC) regarding the recovery of costs related to power supply obligations and state energy programs. The PUC decided that these costs should be recovered volumetrically from all ratepayer classes, except for one category, which should be recovered using a fixed customer charge. IECG argued that the order was preempted by the Federal Power Act and that the allocation and design violated cost-causation principles and state statutes.The Office of the Public Advocate contended that IECG’s appeal was untimely and should be dismissed. The PUC argued that the appeal was an improper collateral attack on a prior rate order. Both the Public Advocate and the PUC maintained that if the merits were considered, the order should be affirmed as rational and supported.The Maine Supreme Judicial Court concluded that the appeal was timely and not barred by collateral estoppel. The court did not address the preemption argument, finding it unpreserved for appellate review. The court rejected IECG’s arguments on the merits, noting the deferential standard of review for the PUC’s expert judgment in ratemaking. The court found that the PUC’s decision to treat NEB costs separately from traditional T&D service costs was rational and supported by the record. The court also determined that the PUC’s allocation and rate design did not violate state statutes.The court affirmed the PUC’s order, holding that the PUC’s approach to NEB cost recovery was within its broad discretion and sufficiently justified. The court noted that the PUC might refine its approach in the future based on further data collection and party input. View "Industrial Energy Consumer Group v. Public Utilities Commission" on Justia Law