Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the order of the superior court affirming the decision of the Maine State Police (MSP) to withhold documents sought by Appellant pursuant to a Freedom of Access Act (FOAA) request, see Me. Rev. Stat. 1, 400-414, holding that the trial court correctly interpreted the FOAA.Appellant submitted a FOAA request to the MSP seeking several documents. The MSP denied his request as to certain documents but provided approximately 6,800 pages of requested materials in full. Appellant appealed, arguing that the superior court erred in determining that the records withheld by the MSP, including DNA contamination logs and quality assurance records, were confidential under state law. The Supreme Judicial Court affirmed, holding that the superior court did not err in (1) its creation of a factual record; and (2) determining that the MSP met its burden to show that the withheld records were confidential. View "Fairfield v. Maine State Police" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing Plaintiff's action for breach of contract and awarding Defendant attorney fees, holding that the district court abused its discretion.The parties in this case formerly lived together at a Saco residence. When they closed on the property the parties entered a contract where, in exchange for Plaintiff assuming responsibility for the down payment, Defendant agreed to assume a greater share of other expenses. Defendant later moved out of the property and filed a partition action, denying the existence of a contract. Plaintiff brought this action alleging breach of contract. On the same day, Plaintiff filed a motion to consolidate the parties' partition, and contract claims. The district court granted Defendant's motion to dismiss and awarded her attorney fees. The Supreme Judicial Court vacated the judgment below, holding (1) the district court abused its discretion by failing to consolidate the two actions; and (2) because Defendant never pleaded abatement, the district court erred in applying the remedy sua sponte. View "Indorf v. Keep" on Justia Law

The Supreme Judicial Court dismissed this appeal from a superior court order denying Appellants' Me. R. Civ. P. 80B petition seeking a review of the decision of the City of Portland to classify Appellants' proposed modification to the Portland City Charter, holding that the appeal was moot.At issue was the City's decision classify the modification to the Portland City Charter, proposed by Appellants - Fair Elections Portland, Inc. and ten individual voters - as a "revision" of, instead of an "amendment" to, the charter. The proposed modification, which would establish a public financing mechanism for city elections, was approved by voters in November 2022. The Supreme Judicial Court dismissed Appellants' appeal, holding that the appeal was moot and that none of the exceptions to the mootness doctrine applied. View "Fair Elections Portland, Inc. v. City of Portland" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered upon Defendant's conditional guilty plea after the trial court denied his motion to suppress evidence obtained through a police officer's interactions with him in a convenience store parking lot, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant moved on multiple grounds to suppress evidence obtained as a result of his interactions with the police officer, arguing that he was unlawfully seized based on an unreliable anonymous tip and was directed to perform field sobriety testing without given a chance to decline. The court denied the motion to suppress. Defendant then entered a conditional guilty plea to operating under the influence. The Supreme Judicial Court affirmed, holding that the officer did not violate the United States Constitution by conducting field sobriety tests under the circumstances of this case. View "State v. Wilcox" on Justia Law

The Supreme Judicial Court affirmed the order of the Public Utilities Commission denying the petition of Maine Coalition to Stop Smart Meters for reconsideration of a previous order approving revised terms and conditions for the smart-meter opt-out program created by Central Maine Power (CMP), holding that there was no abuse of discretion.The revised terms and conditions of the smart-meter opt-out program at issue allowed CMP to install solid-state meters, which are smart meters with the transmitting function disabled, instead of electromechanical (analog) meters for opt-out customers. The Coalition filed a petition for reconsideration. The Supreme Court affirmed, holding (1) the Commission's finding that solid-state meters are safe was not supported by substantial evidence; and (2) the Commission's decision to approve the revised terms was not arbitrary or unreasonable, unjust, or unlawful and was supported by competent evidence in the record. View "Maine Coalition to Stop Smart Meters v. Public Utilities Comm'n" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for two counts of intentional or knowing murder but vacated Defendant's two concurrent life sentences and remanded the case for resentencing, holding that Defendant's sentences were improper.Specifically, the Supreme Judicial Court held that the trial court (1) committed harmless error in admitting evidence of the victim's intention to seek a protection order against Defendant; (2) did not commit obvious error by not, sua sponte, striking the prosecutorial argument in closing implying that Defendant had a burden of proof or by not delivering a limiting instruction; and (3) erred by improperly taking domestic violence into account when setting the basic term of imprisonment for the crimes because a consideration of domestic violence belongs only in the second step of the sentencing process when the court weighs aggravating and mitigating factors. View "State v. Penley" on Justia Law

The Supreme Judicial Court vacated a portion of the divorce judgment entered by the district court in this case and otherwise affirmed, holding that the trial court failed to make the specific finding required by statute establishing why it was equitable and just to allocate a tax exemption to the parent without primary residency.The amended divorce judgment at issue granted Husband contact with the parties' two children three weekends per month, ordered Husband to pay child support, and allocated one child dependency tax exemption to Husband. The Supreme Judicial Court vacated in part and affirmed in part the judgment below, holding that the district court (1) did not abuse its discretion in its allocation of overnight child contact; (2) did not abuse its discretion in declining to make the award of child support retroactive; and (3) erred in its allocation of the child dependency exemptions. View "Proctor v. Childs" on Justia Law

The Supreme Judicial Court affirmed the final judgment and order of the district court in Husband's divorce from Wife and imposed sanctions, holding that Husband's appeal was frivolous and contumacious within the meaning of M. R. App. P. 13(f).On appeal, Husband contended that the trial court both violated his rights to due process by failing to hold a trial and made impermissible changes to the parties' mediation agreement. The Supreme Judicial Court affirmed, holding (1) there was no violation of Defendant's due process rights; (2) the final divorce judgment accurately incorporated the terms of the parties' agreement; and (3) Husband should be sanctioned for this frivolous and contumacious appeal. View "Aubuchon v. Blaisdell" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of stalking, violation of a protective order, and violation of a condition of release, holding that the trial court did not err or abuse its discretion in allowing the victim to identify Defendant as the individual who was telephoning her and threatening her.The victim was a female human resources staffer who terminated Defendant's employment. On appeal, Defendant argued that the trial court abused its discretion in allowing the victim to testify that Defendant was the person who was telephoning the victim because her lay opinion testimony lacked the foundational requirements for admission. The Supreme Judicial Court affirmed, holding that the trial court's allowance of the victim's testimony identifying Defendant as the caller was neither unlawful nor an abuse of discretion. View "State v. Gibb" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court on Appellant's complaint for divorce from Appellee, holding that the trial court's findings were insufficient to support the parental rights portions of the judgment and that the court erred in determining Appellee's income.On appeal, Appellant argued, among other things, that the court's orders concerning parental rights and responsibilities, the parties' child's residence, and Appellee's contact with the child constituted an abuse of discretion. The Supreme Judicial Court agreed and vacated the judgment below, holding (1) remand was required for the trial court to issue an amended judgment that included additional findings as necessary to set forth the basis for the same or different determinations regarding parental rights and responsibilities, contact, and residence; and (2) the record did not support the court's finding that Appellee's annual gross income was only $24,666. View "Whitmore v. Whitmore" on Justia Law