Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the district court dismissing Key Bank National Association's complaint for foreclosure because the debtor or the debtor's estate was a necessary party and was not participating in the action, holding that neither the debtor nor the debtor's estate was a necessary party to the action.The debtor borrowed money from KeyBank and executed a promissory note for the loan. After the debtor died intestate the property at issue passed by operation of law to the debtor's wife as a surviving joint tenant. After the note went into default the wife conveyed the property to a third party. Thereafter, embank filed a complaint for foreclosure of the property against the debtor's wife and estate, as well as third party. The trial court dismissed the action without prejudice, holding that either the debtor or his estate must be named as a necessary party to the foreclosure action. The Supreme Judicial Court vacated the dismissal, holding that because a foreclosure does not include a claim for a deficiency judgment and is therefore solely in rem in nature any mortgagor or successor in interest is a necessary party but a deceased debtor is not. View "KeyBank National Ass'n v. Keniston" on Justia Law

The Supreme Judicial Court vacated in part the district court's amended divorce judgment in this action involving the modification of a divorce judgment, holding that the court erred in calculating child support by imputing an income to Mother that was higher than her actual income.The divorce judgment awarded Mother and Father shared parental rights and responsibilities as to their two children and allocated primary physical residence to Mother. Both parties later filed motions for contempt and Father moved to modify the judgment as to the children's residence, child support, and his rights of contact. The court granted Father's motion to modify and entered an amended divorce judgment. On appeal, Mother argued that the court erred in failing to find that her income was $37,287. The Supreme Judicial Court vacated the court's child support judgment and remanded the case, holding that the court's findings were insufficient to allow for effective appellate review because they did not indicate the court's basis for imputing income to Mother. View "Perreault v. Vallieres" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court entered upon a jury verdict in favor of Mainely Media, LLC on the tort claims brought by Norman Gaudette, a former Biddeford police officer, and his wife Joanne, holding that the trial court did not abuse its discretion in admitting certain testimony.The Gaudettes brought this action claiming defamation, false light, and loss of consortium alleging that Mainely Media had published incorrect information indicating that Norman had sexually abused minors years earlier while he was a police officer. The trial court entered judgment in favor of Mainely Media. On appeal, the Gaudettes argued that the trial court abused its discretion by refusing to strike a detective's testimony that an earlier investigation of Norman did not exonerate him. The Supreme Judicial Court affirmed, holding that the superior court did not abuse its discretion when it admitted the detective's testimony. View "Gaudette v. Mainely Media, LLC" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault but vacated his sentence of eight years' imprisonment to be followed by eight years of supervised release, holding that there was no error in Defendant's conviction but that the sentencing analysis used by the trial court resulted in obvious error that required correction.On appeal, Defendant argued that the trial court committed obvious error in its treatment of a note from the jurors during jury deliberations and because of prosecutorial error. The Supreme Judicial Court remanded the case for resentencing, holding (1) Defendant waived any objection to the court's response to the note; (2) there was no prosecutorial error or impropriety; and (3) the lower court had the authority to impose what was a lawful amended sentence, but the sentencing analysis employed by the court required that this Court vacate the sentence and remand for a de novo sentencing hearing. View "State v. Cummings" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court that reversed and modified the decision of the tax assessor of the Town of Vinalhaven denying Hurricane Island Foundation a local property tax exemption under Me. Rev. Stat. 36, 652(1)(B), holding that the Town's tax assessor correctly denied the tax exemption.In denying the Foundation's application, the Town's tax assessor concluded that the Foundation failed to meet the standard for a "literary and scientific" institution under the statute. The superior court twice remanded the case. For both the second and the third time, the assessor denied the tax exemption to the Foundation. The superior court modified the decision to designate the Foundation as tax exempt, concluding that there was an error of law in the assessor's decision. The Supreme Judicial Court vacated the judgment below and remanded for the court to enter a judgment declaring that the Foundation was not exempt, holding that the Foundation failed to show it was a "scientific" institution. View "Hurricane Island Foundation v. Town of Vinalhaven" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for aggravated assault, robbery, domestic violence assault, domestic violence criminal threatening, and theft by unauthorized taking or transfer but reversed his sentence, holding that the trial court erred by failing to merge duplicative counts.The Supreme Judicial Court remanded this case for resentencing, holding (1) the trial court did not err in failing to give a specific unanimity instruction in addition to the given general unanimity instruction; (2) the trial court erred in failing to merge the duplicative counts of theft by unauthorized taking or transfer and robbery, resulting in a double-jeopardy violation; and (3) the trial court's reliance on Defendant's decision to seek a trial as an aggravating factor in his sentence was unconstitutional. View "State v. Chase" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for three counts of intentional or knowing murder, among other crimes, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant challenged the decision of the trial court to admit a statement that he made to police in which he identified the number and names of his victims and argued that the trial court committed obvious error by instructing the jury on the thirty-party provocation exception to the use of deadly force. The Supreme Judicial Court affirmed, holding (1) any error in admitting Defendant's challenged statement was harmless beyond any reasonable doubt; and (2) the trial court did not commit obvious error by reciting a portion of the self-defense statute that was not generated by the evidence. View "State v. Bonfanti" on Justia Law

The Supreme Judicial Court vacated the decision of the Town of Ogunquit Board of Appeals concluding that good cause existed for this appeal brought by Appellant pursuant to Me. R. Civ. P. 80B challenging the issuance of building permits by the Town's code enforcement officer (CEO) to 477 Shore Road LLC, holding that the Board erred.At issue was the issuance of building permits to the LLC of construction relating to six single-family dwelling units. Appellant, who owned property abutting the LLC's parcel, filed a complaint requesting an injunction, a writ of mandamus, and a declaratory judgment. The complaint was denied. While Appellant's appeal was pending (Tominsky I), the CEO issued a certificate of occupancy for one of the dwelling units. Appellant appealed the issuance of the certificate, but the Board voted not to hear the appeal. Appellant then filed a second complaint containing multiple counts against the Town and the LLC (Tominsky II). The superior court denied Appellant's appeal in Tominsky I and dismissed the appeal in Tominsky II. The Supreme Judicial Court vacated the judgment in Tominsky I and affirmed the judgment in Tominksy II, holding (1) the appeal in Tominsky I before the Board was untimely; and (2) the appeal in Tominsky II failed to allege a viable claim for relief. View "Tominsky v. Town of Ogunquit" on Justia Law

The Supreme Judicial Court vacated the judgment of divorce entered by the district court as to the disposition of certain property and the dissolution of Cole G. Bridges Wild Blueberry LLC, holding that the circuit court lacked jurisdiction to order the dissolution of the LLC and erred in setting aside certain property to Cole Bridges.In 2020, Candy Littell filed for divorce from Bridges. The district court granted the divorce. On appeal, Bridges argued that the district court erred in evaluating and classifying a Cessna airplane and lacked jurisdiction to dissolve the LLC. The Supreme Judicial Court vacated the judgment in part and remanded the case, holding (1) the court did not have jurisdiction over the LLC and thus could not order its dissolution; and (2) the court erred in its classification and valuation of the Cessna airplane. View "Littell v. Bridges" on Justia Law

The Supreme Judicial Court vacated the judgment entered in the district court granting Pat Doe a protection from abuse (PFA) order against Thomas Lindahl, holding that remand was required.In January 2022, Doe filed her first PFA. The complaint was denied because Doe failed to prove her allegations. In April 2022, Doe filed the PFA complaint at issue. After the hearing, the trial court granted the PFA for one year, finding that there was a basis to Plaintiff's complaint under Me. Rev. Stat. 19-A, 4002(1)(B). The Supreme Judicial Court vacated the order, holding (1) the court's finding of abuse relied upon an erroneous assumption that the events Doe described as happening on April 22, 2022 occurred on May 13 2022, in violation of an amended temporary protection order; and (2) therefore, remand for clarification was required. View "Doe v. Lindahl" on Justia Law