Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant's conviction of, among other charges, seventeen counts of sexual exploitation of a minor under the age of twelve, holding that a search of Defendant's smartphone did not violate Defendant's rights under the Fourth Amendment.On appeal, Defendant argued that the trial court abused its discretion when it declined to reach its argument that the warrant supporting the search of his cellphone was overbroad and violated the particularity requirement of the Fourth Amendment. The Supreme Judicial Court disagreed and affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress; and (2) Defendant's remaining arguments on appeal were without merit. View "Maine v. Jandreaud" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing with prejudice Grandmother's complaints for determination of de facto parentage concerning her two minor grandchildren, holding that the best interests determinations required in guardianship actions and in actions for de facto parentage are distinct determinations.The district court determined that issue preclusion completely barred Grandmother's claims for de facto parentage because the issue of the child's best interests was already decided in a prior consolidated proceeding on competing guardianship petitions. The Supreme Court vacated the judgment below and remanded the matter for the court to consider Grandmother's standing with respect to her complaints for de facto parentage, holding that issue preclusion did not prevent the court from considering Grandmother's complaints for de facto parentage because the best interests determinations required in a guardianship proceeding are not identical to those in a proceeding for de facto parentage. View "Gardner v. Greenlaw" on Justia Law

The Supreme Judicial Court vacated the judgment of the business and consumer docket entered in favor of Plaintiffs vacating the Bureau of Parks and Lands' lease of public reserved land to NECEC Transmission LLC and Central Maine Power Co. (CMP) for construction of a high-capacity transmission line, holding that the Bureau acted within its constitutional and statutory authority in granting the lease.CMP appealed and Plaintiffs cross-appealed the trial court's decision not to address the substantive question of whether the Bureau had the constitutional authority to lease to the public reserved land. Plaintiffs later moved to dismiss the appeals on the ground that a citizen's initiative rendered the appeals moot. The Supreme Judicial Court denied the motion to dismiss and vacated the judgment below, holding (1) retroactive application of section 1 of the Initiative did not violate the Contract Clause of the United States Constitution, and therefore, the lease was not voided by the initiative; and (2) the record established that the Bureau acted within its constitutional and statutory authority in granting the lease. View "Black v. Bureau of Parks & Lands" on Justia Law

The Supreme Judicial Court vacated the judgment of foreclosure and order of sale entered by the district court in favor of Plaintiffs on their complaint for residential foreclosure, holding that Plaintiffs failed to establish each statutory requirement for summary judgment of foreclosure as outlined in Me. R. Civ. P. 56(j).When a case is in the Foreclosure Division Program, as was the instant case, one statutory requirement that must be established by the movant is completion of mediation. On appeal, Defendant argued that Plaintiffs did not prove that mediation was completed, as required by statute, and that vacatur was required. The Supreme Judicial Court vacated the judgment below, holding that summary judgment was error because it was apparent from the court record that mediation had not been completed. View "Janusz v. Bacon" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court striking Mother's "motion to reopen evidence" on Father's motion to modify child support because she failed to pay a filing fee, holding that Mother was not required to pay a filing fee.More than a decade after the parties divorced, Father filed a motion to modify child support seeking a reduction in his support obligation because the parties' oldest child had graduated from high school. The trial court granted the motion. Mother later filed her motion to reopen evidence asserting that she had discovered evidence showing that Father's actual income was significantly higher than the income imputed to him by the trial court in its order. The trial court struck the motion as incomplete for lack of a filing fee. The Supreme Judicial Court vacated the judgment below, holding that Mother's motion was exempt from the filing fee. View "Davies v. Davies" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for attempted murder, aggravated assault, and other crimes following a nonjury trial, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court failed adequately to consider the evidence that he was suffering from a serious mental abnormality and that there was insufficient evidence to prove intent beyond a reasonable doubt. The Supreme Judicial Court agreed and affirmed, holding (1) the evidence supported the trial court's finding that Defendant was not suffering from an abnormal condition of the mind that raised a reasonable doubt as to whether he acted intentionally when he shot the victim; and (2) the court did not err in finding that Defendant failed to meet his burden of proof on his affirmative insanity defense. View "State v. Hallowell" on Justia Law

The Supreme Judicial Court vacated the judgment of conviction of attempted murder and other offenses entered by the trial court, holding that multiple acts of prosecutorial error occurred in this case, requiring remand for a new trial.A jury found Defendant guilty of attempted murder, elevated aggravated assault, robbery, and reckless conduct with a dangerous weapon. On appeal, Defendant principally argued that the trial court erred in denying his repeated motions for a mistrial based on allegedly improper comments made during the prosecution's opening statement, closing statement, and rebuttal. The Supreme Judicial Court agreed and remanded the case for a new trial, holding (1) the State committed error in its opening statement and closing argument; and (2) because Defendant's substantial rights were impaired, under Me. Const. art. I, 6 and 6-A and this Court's supervisory power, the appropriate remedy in this case was a new trial. View "State v. White" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court granting Wife's complaint for divorce, holding that the trial court's factual findings were not supported by competent record evidence.On appeal, Husband argued that the trial court erred in determining that a 1968 Ford Mustang was a gift to Wife and setting it aside for her as her nonmarital property and in awarding a 2013 Honda Rancher to Wife. The Supreme Judicial Court vacated the judgment below, holding (1) because the parties did not present evidence of under what circumstances the 1968 Ford Mustang was acquired the trial court lacked an adequate evidentiary basis from which it could award the vehicle to set it aside for one of the parties; and (2) because there was no evidence that the parties owned a 2013 Honda Rancher at the time of the final hearing the trial court erroneously awarded one to Wife. View "Mitchell v. Mitchell" on Justia Law