Justia Maine Supreme Court Opinion Summaries

Heather M. Hodgson was charged with several offenses following an incident at her home involving her husband and their two children. The dispute began after her husband purchased alcohol, which upset Hodgson. Both consumed alcohol, and an argument ensued. During the altercation, Hodgson pointed a loaded firearm at her husband and fired a “warning shot” at the floor near his feet. The couple’s three-year-old child was present in the home and had come out of the bedroom during the argument. Hodgson was subsequently indicted on multiple charges, including domestic violence reckless conduct with a dangerous weapon, domestic violence criminal threatening with a dangerous weapon, and endangering the welfare of a child.The case was tried without a jury in the Kennebec County Unified Criminal Docket. After the State presented its evidence, Hodgson moved for acquittal on some counts, which the court granted in part. Hodgson testified, claiming self-defense, but the court found her account not credible. The court found her guilty on three counts: domestic violence reckless conduct with a dangerous weapon, domestic violence criminal threatening with a dangerous weapon, and endangering the welfare of a child. At sentencing, the court declined to impose the mandatory minimum one-year sentence for the reckless conduct charge, instead sentencing Hodgson to three years with all but ninety days suspended and probation.On appeal, the Maine Supreme Judicial Court reviewed both Hodgson’s challenge to the sufficiency of the evidence and the State’s appeal regarding the sentence. The Court affirmed Hodgson’s convictions, finding the evidence sufficient. However, it held that the trial court erred by not imposing the mandatory minimum one-year sentence required by statute for domestic violence reckless conduct with a dangerous weapon. The Court vacated the sentence for that count and remanded for resentencing consistent with the statutory requirement. View "State v. Hodgson" on Justia Law

Law enforcement in Maine received a tip from a confidential source about suspicious rental car activity by Calvin Vandine, who was known to use drugs and associate with traffickers. Officers tracked Vandine’s movements and, based on the tip and corroborating information, stopped his car, which was also occupied by Derric McLain. During the stop, officers found drugs and arrested both men. McLain was later identified as having outstanding warrants, including for drug trafficking. The stop lasted about twenty-eight minutes, and a subsequent search revealed significant quantities of controlled substances.Prior to trial in the Penobscot County Unified Criminal Docket, McLain moved to suppress evidence from the stop and statements made during custodial interrogation, arguing lack of reasonable suspicion for the prolonged detention and that he had not waived his privilege against self-incrimination. The trial court (Anderson, J.) denied the motion to suppress, finding the stop justified and the statements admissible. After a jury trial before Justice Murray, McLain was convicted of aggravated drug trafficking and violation of condition of release, receiving a substantial sentence.On appeal, the Maine Supreme Judicial Court reviewed the denial of the suppression motion. The Court affirmed the lower court’s findings that the stop, search, and arrest were supported by reasonable suspicion and were not unconstitutionally prolonged. However, the Court held that McLain did not clearly waive his privilege against self-incrimination under article I, section 6 of the Maine Constitution, as his responses during interrogation were ambiguous and officers failed to clarify his intent. The Court vacated the conviction and the suppression order in part, remanding for further proceedings, and established that a clear and unequivocal waiver is required before custodial interrogation may proceed in Maine. View "State v. McLain" on Justia Law

A group of seven property owners and part-time residents in Northeast Harbor challenged the approval of a six-unit subdivision proposed by Mount Desert 365 (MD 365) on a 0.9-acre parcel. The subdivision, called Heel Way, was designed to provide workforce housing and consisted of two double-dwelling-unit buildings and two single-dwelling-unit buildings on a commonly owned lot. The Town of Mount Desert Planning Board held nine meetings, considered input from the developer, residents, and the public, and ultimately approved the application in October 2023, issuing a written decision in December 2023.The residents sought judicial review in the Maine Superior Court, which transferred the case to the Business and Consumer Docket. In June 2024, the Business and Consumer Docket affirmed the Planning Board’s decision, and the residents appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the Planning Board’s decision directly, applying de novo review to the ordinance interpretation. The Court held that the Planning Board correctly determined that the subdivision did not create separate lots and thus did not need to meet access-road requirements. The Planning Board also did not abuse its discretion in waiving the performance bond in favor of a conditional agreement. The Court affirmed the Planning Board’s calculation of density requirements, finding no error in its methodology.However, the Court found that the Planning Board erred by declining to calculate the open-space requirements under the Town’s Subdivision Ordinance. The Court vacated the judgment and remanded the matter to the Business and Consumer Docket with instructions to remand to the Planning Board for further consideration of the open-space calculation. View "Cannon v. Town of Mount Desert" on Justia Law

A condominium association challenged the validity of a property transaction involving a shorefront parcel that was originally added to the condominium by the declarant, who had expressly reserved development rights, including the right to withdraw land. After the original declarant’s unsuccessful development efforts, the property and associated development rights were transferred to a lender and then to a successor declarant. The successor declarant withdrew the shorefront parcel from the condominium and conveyed it to another entity without obtaining the written consent of 80% of the unit owners. The association argued that this withdrawal and conveyance violated the Maine Condominium Act and sought to have the transaction set aside, as well as to recover attorney fees.The Business and Consumer Docket (a Maine trial court) granted partial summary judgment in favor of the defendants, concluding that the withdrawal and conveyance were valid exercises of the declarant’s reserved development rights under the condominium declaration and the Maine Condominium Act. The court denied the association’s motion for summary judgment and set remaining claims for trial. On the day of trial, the parties reached a settlement, which was incorporated into a final judgment. The settlement preserved the association’s right to appeal the summary judgment ruling on the withdrawal of the shorefront parcel.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court’s judgment. The court held that a declarant’s properly reserved development rights, including the right to withdraw land, are not subject to the statutory requirement that 80% of unit owners approve the withdrawal of common elements. The court also rejected the association’s claim for attorney fees, finding that the parties’ settlement agreement foreclosed such a claim. View "The Village at Ocean's End Condominium Association v. Southwest Harbor Properties LLC" on Justia Law

A police officer in Pittsfield, Maine, stopped Michael L. Kilgore for speeding and discovered possible license restrictions. During the stop, Kilgore became agitated, drove away while the officer was standing next to his vehicle, and ran over her foot. After a pursuit, Kilgore was apprehended following a physical altercation with the officer, during which he kicked and punched her before being subdued. The officer suffered injuries requiring medical attention. Kilgore was charged with multiple offenses, including aggravated assault, assault on an officer, and several related charges.The Somerset County Unified Criminal Docket held a jury trial. The jury found Kilgore guilty of assault on an officer (Class C) and the lesser included offense of assault (Class D), but acquitted him of aggravated assault and other charges. The trial court merged the assault conviction into the assault on an officer conviction and sentenced Kilgore to forty-two months in prison, with all but nine months suspended, followed by probation. Kilgore appealed, arguing that the jury instructions were flawed because they failed to properly inform the jury of the State’s burden to disprove the defenses of self-defense, duress, and competing harms beyond a reasonable doubt, and did not instruct the jury to acquit if the State failed to meet that burden.The Maine Supreme Judicial Court reviewed the case for obvious error. The Court found that the trial court’s jury instructions contained two significant errors: they allowed the jury to find Kilgore guilty based solely on the elements of the offenses without considering the generated defenses, and they failed to instruct the jury to acquit if the State did not disprove duress and competing harms. The Court held that these errors were plain, affected Kilgore’s substantial rights, and undermined the fairness of the proceedings. The judgment was vacated and the case remanded for a new trial. View "State of Maine v. Kilgore" on Justia Law

The case involved a defendant who lived with his spouse, her daughter (the victim), and her younger sons in Wiscasset, Maine, from 2019 to 2022. The victim, beginning at age eight and continuing until nearly twelve, testified that the defendant repeatedly sexually assaulted her, describing both generic and three specific incidents. The assaults included acts in the defendant’s bedroom, during a family bonfire, and in a car. The victim disclosed the abuse to her mother and a friend, which led to a police investigation. The defendant was charged with gross sexual assault and violating a condition of release, with the alleged conduct occurring between January 2020 and July 2022.The Lincoln County Unified Criminal Docket held a jury trial for the gross sexual assault charge and a nonjury trial for the violation of release. The State’s evidence consisted primarily of the victim’s testimony, supported by her mother and the investigating detective. The defendant did not testify or present evidence. Both parties reviewed and did not object to the court’s draft jury instructions, which included a general unanimity instruction but not a specific unanimity instruction regarding the factual basis for conviction. The jury found the defendant guilty of gross sexual assault, and the court found him guilty of violating a condition of release. The defendant was sentenced to eighteen years in prison for gross sexual assault and six months for the release violation, to run concurrently.On appeal, the Maine Supreme Judicial Court reviewed whether the absence of a specific unanimity instruction and certain statements by the prosecutor during closing arguments constituted obvious error. The court held that, although the lack of a specific unanimity instruction was plain error, it did not affect the defendant’s substantial rights given the nature of the evidence and arguments. The court also found that any prosecutorial error in closing arguments did not rise to the level of obvious error. The judgment was affirmed. View "State of Maine v. Schooley" on Justia Law

The defendant was convicted of two counts of unlawful sexual contact and one count of unlawful sexual touching involving his niece by marriage, who was a minor at the time. The incidents occurred in 2020 at the defendant’s home in West Gardiner, Maine, when the victim was left alone with him during family gatherings. The victim later disclosed the abuse in a forensic interview at a Children’s Advocacy Center (CAC), which was video recorded. The State charged the defendant in March 2022, and after a grand jury indictment, the case proceeded to trial. The defendant was subject to bail conditions restricting contact with minors.Prior to trial in the Kennebec County Unified Criminal Docket, the defendant moved for a bill of particulars and later asserted his right to a speedy trial, which he temporarily waived to obtain out-of-state records. He renewed his speedy trial demand, but delays occurred due to both his requests for specific trial dates and court scheduling constraints. The trial court denied his motion to dismiss for a speedy trial violation, finding that the delays were attributable to both parties and that the prejudice suffered was insufficient to warrant dismissal. The court also admitted the CAC video under 16 M.R.S. § 358, over the defendant’s objections based on confrontation and due process rights, and after editing out most references to uncharged conduct. The jury found the defendant guilty of the counts related to West Gardiner and not guilty of those related to Augusta.On appeal, the Maine Supreme Judicial Court reviewed the denial of the speedy trial motion, the admission of the CAC video, and the applicability of section 358. The Court held that there was no violation of the defendant’s speedy trial rights under either the Maine or United States Constitutions, that the admission of the CAC video did not violate the Maine Confrontation Clause or Due Process Clause, and that the amended version of section 358 applied to the case. The judgment of conviction was affirmed. View "State of Maine v. Engroff" on Justia Law

In 2023, the Maine Legislature enacted the Paid Family and Medical Leave (PFML) program, requiring employers to remit quarterly premiums into a state fund beginning January 1, 2025. The program allows covered individuals to take up to twelve weeks of leave for qualifying reasons, with benefits paid from the fund. Employers may apply to substitute an approved private plan that provides substantially equivalent benefits, which exempts them from further premium payments. The Maine Department of Labor adopted rules implementing the PFML program, including a provision that all employers must pay nonrefundable premiums for the first quarter of 2025, even if they later obtain approval for a private plan. Employers could begin applying for private plan approval after April 1, 2025, due to the time needed for insurers to develop compliant policies.The Maine State Chamber of Commerce and Bath Iron Works challenged the Department’s rule requiring nonrefundable premiums, arguing it conflicted with the PFML Act and constituted an unconstitutional taking under both the Maine and U.S. Constitutions. The Kennebec County Superior Court accepted a consented-to motion to report three legal questions to the Maine Supreme Judicial Court: whether the rule conflicted with the Act or was arbitrary and capricious, and whether it constituted a taking under state or federal law.The Maine Supreme Judicial Court accepted the report and held that the Department’s rules do not conflict with the PFML Act and are not arbitrary, capricious, or otherwise unlawful. The Court found that the statute unambiguously requires employers to remit premiums until a private plan is approved, and the rules reasonably implement the legislative intent. Additionally, the Court determined that the obligation to pay premiums does not constitute a cognizable taking of private property under either the Maine or U.S. Constitution. The Court answered all three reported questions in the negative and remanded the case for further proceedings. View "Maine State Chamber of Commerce v. Department of Labor" on Justia Law

A man was involved in an incident at a fast-food restaurant where, after displaying what appeared to be an assault rifle and making a threatening remark to a cashier, he was reported to the police. Officers located him in his car in a nearby parking lot. Believing he was armed and dangerous, police initiated a high-risk stop, ordering him to exit his vehicle. He refused repeated commands to leave the car, instead yelling at officers and behaving aggressively. Over the course of more than two hours, law enforcement—including a negotiator and SWAT team—attempted to persuade him to exit. Ultimately, officers used chemical agents and a flash device to remove him from the vehicle, where they found the rifle described by the cashier.The man was charged with several offenses, including creating a police standoff under Maine law. At trial in the Cumberland County Unified Criminal Docket, the jury heard testimony from witnesses and law enforcement. After the State rested, the defendant moved for acquittal, arguing insufficient evidence for the police standoff and criminal threatening charges. The court denied the motion. The jury found him guilty of creating a police standoff but not guilty of the other charges. He was sentenced to time already served. The defendant then filed a renewed motion for acquittal, again challenging the sufficiency of the evidence and the interpretation of the term “barricaded” in the relevant statute. The trial court denied this motion as well.On appeal, the Maine Supreme Judicial Court reviewed the statutory interpretation of “barricaded” and the sufficiency of the evidence. The Court held that the trial court correctly applied the plain meaning of “barricaded” and that sufficient evidence supported the jury’s findings on all elements of the offense. The judgment of conviction was affirmed. View "McKusick v. State of Maine" on Justia Law

The case concerns a defendant who, after consuming a large quantity of alcohol over several hours at a restaurant, drove his vehicle and struck an elderly pedestrian, causing serious injuries. The defendant left the scene after briefly stopping. The incident was reported to police, and evidence, including GPS data and crash reconstruction, indicated the defendant was speeding, crossed into the opposite lane, and that his alcohol consumption contributed to the crash. Due to a delay in identifying the defendant, no chemical test of his blood-alcohol concentration (BAC) was performed at the time of the accident.The State initially charged the defendant with aggravated assault and leaving the scene of an accident involving serious bodily injury or death. A grand jury later indicted him on additional charges, including aggravated operating under the influence (OUI). The State notified the defendant that it would use expert testimony based on the Widmark formula to estimate his BAC at the time of the crash, given the absence of a chemical test. The defendant moved to exclude this testimony, but the trial court allowed the State’s chemist to testify that the defendant’s BAC exceeded .08, while prohibiting the chemist from giving an exact number or invoking statutory presumptions of intoxication. The jury found the defendant guilty on all counts, and the trial court denied his motion for acquittal.The Maine Supreme Judicial Court reviewed the case. It held that Maine’s OUI statutes do not require a chemical test as the exclusive means of proving BAC and permit the use of reliable expert opinion testimony, such as that based on the Widmark formula. The Court also found that the expert’s testimony was sufficiently tailored to the facts and thus admissible. Additionally, the Court concluded that the evidence was sufficient to support the aggravated assault conviction. The judgment was affirmed, with a remand to correct the sentencing record to reflect concurrent sentences. View "State of Maine v. MacKenzie" on Justia Law