Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court vacated in part the judgment of the district court ordering Husband's divorce from Wife and awarding sole parental rights and responsibilities of the parties' two children to Wife, holding that the trial court abused its discretion in ordering that Husband disclose all counseling records to Wife in order to have contact with their children.Six to seven years before Wife filed the complaint for divorce Husband's mental health began deteriorating. The trial judge granted Wife a divorce, ordered that Wife would have sole parental rights and responsibilities of the children, and ordered that Husband provide his counseling records to Wife to help convince Wife to allow visitation with the children and when this should occur. The Supreme Judicial Court vacated the judgment in part, holding that the term "counseling records" could include information that Wife may not have a right to access under federal and state law, and therefore, the district court abused its discretion in imposing this condition. View "Doe v. Walsh" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing Appellant's complaint for lack of personal jurisdiction over Defendant, holding that Maine had personal jurisdiction over Defendant in this case.Plaintiff was a Delaware limited liability company with its principal place of business in Maine. Defendant was a Delaware corporation with its principal place of business in California. Plaintiff brought this action asserting a claim of tortious interference with contractual and advantageous economic relations against Defendant. The district court dismissed the complaint on the ground that Maine lacked jurisdiction over Defendant. The Supreme Judicial Court vacated the judgment below, holding that all of the due process requirements were met, and therefore, the trial court had specific personal jurisdiction over Defendant. View "Premier Diagnostics v. Invitae Corp." on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing Plaintiff's tort complaint against Defendant, the firm that represented her ex-husband in her complaint for divorce, as being barred by the doctrine of issue preclusion, holding that Plaintiff's tort action was not barred by issue preclusion.During the divorce proceedings, Plaintiff moved for a mistrial on the ground of surprise because Defendant failed to copy her attorney on a subpoena requesting her counseling records from her therapist. A referee denied the motion. After the conclusion of the divorce proceedings, Plaintiff brought this action asserting claims of abuse of process and intentional infliction of emotional distress, alleging that Defendant abused the legal process by obtaining a full set of her counseling records, and the disclosure caused her great distress. Defendant filed a motion to dismiss, arguing that the complaint was barred by res judicata. The trial court determined that Plaintiff was collaterally estopped from pursuing her tort claims. The Supreme Judicial Court vacated the judgment below, holding that Plaintiff's action was not barred by issue preclusion because the referee's findings were not essential to the underlying divorce judgment. View "Pacheco v. Libby O'Brien Kingsley & Champion, LLC" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered in the business and consumer docket in favor of Employee on the parties' cross-motions for summary judgment after the trial court concluded that Employer failed to comply with the state's wage payment and minimum wage laws, holding that the trial court did not err.At issue was whether the trial court erred in concluding that Employer violated the State's wage payment laws when it permitted Employee's paycheck to be deposited into a bank account controlled by "cybercriminals" who had stolen Employee's username and password to the online portal where she designated payroll information. The Supreme Judicial Court affirmed, holding that where there was no dispute of material fact that Employer did not deposit Employee's wages into her bank account, Employee was entitled to summary judgment because Employer failed to "pay" her, thus violating Maine's wage payment laws. View "Dorsey v. Northern Light Health" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for gross sexual assault but remanded for the court to determine the appropriate length and conditions of supervised release to be imposed, holding that there was otherwise no error.Specifically, the Supreme Judicial Court held (1) because a principal and accomplice are not subject to different processes or analyses when a sentencing court applies the Hewey analysis set out in Me. Rev. Stat. 17-A, 1602, the sentencing court did not err when it set the basic sentence at twenty years in compliance with Me. Rev. Stat. 17A-1252(4-E); and (2) remand was required for the district court to determine the length and conditions of supervised release to be imposed and to articulate its analysis and the factors that led to its decision. View "State v. Ringuette" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court dismissing with prejudice Plaintiff's protection from abuse (PFA) case, holding that the court did not err in determining that Plaintiff had agreed to a dismissal with prejudice.In 2018, Plaintiff filed a complaint for PFA against Defendant, whom she was divorcing. The PFA case was included in the divorce settlement negotiations. By the end of 2019, the parties had negotiated a future dismissal with prejudice of the PSA case as part of their final settlement. In 2021, on the eve of the expiration of the agreed-upon, self-terminating order, Plaintiff requested a final evidentiary hearing in the PFA case. The court dismissed the PFA order with prejudice, concluding that Plaintiff agreed that the PFA complaint would be dismissed with prejudice following two years without violation. The Supreme Court affirmed, holding that the trial court did not commit clear error in (1) determining that Plaintiff intended to enter into a binding settlement agreement that would be incorporated into the court's order; and (2) finding that Defendant did not violate the terms of the PFA order. View "Doe v. Hewson" on Justia Law