Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the superior court affirming the judgment of the district court that denied Landlord's forcible entry and detainer (FED) action to oust Tenant from possession of Landlord's property, holding that Tenant's breach of the terms of its lease entitled Landlord to issuance of a writ of possession.The district court concluded that Landlord was not entitled to possession of the subject property because Tenant's failure to pay its rent was at least in part excused by the force majeure clause in the parties' lease. The Supreme Judicial Court vacated the judgment, holding that Tenant's breach of the terms of its lease entitled Landlord to issuance of a writ of possession. View "55 Oak Street LLC v. RDR Enterprises, Inc." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for certain domestic violence incidents, including possession of a firearm by a prohibited person, holding that Defendant was not entitled to relief on his allegations of error.After a jury convicted him of six offenses Defendant appealed, raising several allegations of error. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant's request for sanctions for the State’s alleged discovery violations; (2) the trial court did not commit obvious error by admitting testimony of a police officer, including certain statements under Me. R. Evid. 801(d)(1)(B); (3) the trial court did not abuse its discretion in admitting an unauthenticated letter that Defendant claimed was written on behalf of the victim; (4) the court did not err when it denied Defendant's motion to dismiss because of the makeup of the jury venire; and (5) there was sufficient evidence for the jury to have rationally found that every element of each count Defendant was convicted of was proved beyond a reasonable doubt. View "State v. Thomas" on Justia Law

The Supreme Judicial Court dismissed this appeal from an order entered in the business and consumer document granting a motion to dismiss Plaintiffs' complaint seeking to enforce a prior judgment awarding them damages for their claims against Defendants, holding that the appeal was interlocutory.Plaintiffs recorded writs of execution against Defendants but did not receive payment for the final judgment. Plaintiffs then filed a complaint to commence the enforcement action. Some of the defendants filed a motion to dismiss several counts, which the court granted. The Supreme Judicial Court dismissed the appeal, holding that the appeal was interlocutory and that no exception to the final judgment rule applied. View "Maples v. Compass Harbor Village Condominium Ass'n" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murdering a deputy sheriff and sentencing Defendant to life imprisonment, holding that there was no error.After his conviction, Defendant filed a motion for a new trial on the ground of newly discovered evidence. In the motion, Defendant asserted that a newly discovered disciplinary report concerning a member of the law enforcement team that arrested him could have been used as impeachment evidence at his trial. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) Defendant failed to show the disciplinary report to him was favorable to him in the first instance; and (2) therefore, Defendant failed to show a reasonable probability that the report would have produced a different verdict at trial if it had been admitted into evidence. View "State v. Williams" on Justia Law

The Supreme Judicial Court vacated in part the judgment of the superior court affirming the Board of Environmental Protection's decision to upheld a cleanup order issued by the Commissioner of the Department of Environmental Protection pursuant to Me. Rev. Stat. 38, 1365 against Sultan Corporation for hazardous substances located on its property, holding that the Board improperly declined to address the availability of a third-party defense.In upholding the Commissioner's remediation order the Board expressly declined to reach the issue of whether the third-party defense afforded by Me. Rev. Stat. 38, 1367(3) was available to Sultan in an appeal of a Commissioner's section 1365 order because of the Board's conclusion that even if the defense were available, Sultan failed to prove the elements of the defense by a preponderance of the evidence. The superior court affirmed. The Supreme Judicial Court vacated the portion of the Board's order in which the Board declined to address the availability of the third-party defense, holding that the question of whether the defense was available was a threshold issue that must be determined before the Board or a court can consider the merits of the defense. View "Sultan Corporation v. Department of Environmental Protection" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court suppressing Defendant's blood test results in the State's prosecution of Defendant for operating under the influence, holding that the findings of the court did not support its legal conclusion that Defendant did not voluntarily give his consent.In suppressing the blood test results the trial court concluded that the blood draw was a result of simple acquiescence to the trooper's authority. On appeal, the State argued that the trial court erred in concluding that Defendant did not voluntarily consent to the blood draw. The Supreme Judicial Court agreed and reversed the the trial court's order suppressing the evidence, holding that, in the totality of the circumstances, holding that Defendant's response to the trooper's request objectively manifested free and voluntary consent. View "State v. Croteau" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court that characterized the court's prior order on Appellants' motion for a preliminary injunction as a ruling on the merits and entering a final judgment without holding a hearing, holding that the court's order violated Me. R. Civ. P. 65(b)(2).Appellants filed this complaint alleging violations of the statutory warranty of habitability and an illegal eviction and seeking injunctive and declaratory relief. After a hearing, the court entered an order granting in part and denying in part Appellants' request for a preliminary injunction. Thereafter, Appellants filed a request for default judgment. The court denied the request and then entered the order as a final judgment. The Supreme Judicial Court vacated the judgment below, holding that the order, which treated the hearing on the motion for a preliminary injunction as a consolidated hearing on the motion and on the merits, violated Me. R. Civ. P. 65(b)(2) and offended due process. View "McKeeman v. Duchaine" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Department of Marine Resources (DMR) to grant an aquaculture lease to Mere Point Oyster Company, LLC (MPOC) in Maquoit Bay, holding that there was no error or abuse of discretion.MPOC applied for a ten-year aquaculture lease for a site in Marquoit Bay located near the shorefront property of Maquoit Bay, LLC and its sole members, Paul and Kathleen Dioli (collectively, the Diolis). DMR approved the application. Thereafter, the Diolis filed a Me. R. Civ. P. 80C petition requesting review of DMR's decision. The superior court affirmed. The Supreme Judicial Court affirmed, holding (1) DMR did not err by approving the lease application without requiring MPOC to consider practicable alternatives; (2) DMR did not err by balancing the interests of MPOC and the public pursuant to Me. Rev. Stat. 6072's express requirements; and (3) the Diolis were not entitled to relief on any of their remaining allegations of error. View "Maquoit Bay LLC v. Department of Marine Resources" on Justia Law

The Supreme Judicial Court dismissed this appeal from an order of the Public Utilities Commission (PUC) declining to open a formal investigation into a water bill issued to General Marine Construction Corp. by the Portland Water District (PWD), holding that General Marine's appeal was not taken from a final decision of the Commission pursuant to Me. Rev. Stat. 35-A, 1320(1).At issue was a $15,804 "make-up bill" that the PWD issued to General Marine for unauthorized and unmilled water usage. General Marine filed a complaint challenging the bill. The Commission's Consumer Assistance and Safety Division (CASD) concluded that the PWD had complied with PUC rules in issuing the make-up bill. The Commission upheld CASD's decision. General Marine appealed. The Supreme Judicial Court dismissed the appeal, holding (1) the PUC did not issue a "final decision" at the conclusion of the statutorily-authorized informal process; and (2) therefore, section 1320(1) did not authorize General Marine's appeal. View "General Marine Construction Corp. v. Public Utilities Commission" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court granting summary judgment in favor of the University of Maine System and the University of Maine and dismissing Plaintiff's complaint asserting negligent maintenance and operation of a parking lot, holding that there was no error.Plaintiff slipped and fell on a patch of untreated ice on the University of Maine's Orono campus and sustained injuries. Plaintiff filed this complaint alleging that the University was negligent in its maintenance and operation of the parking lot. The superior court granted summary judgment for the University on the grounds that the parking lot was not an appurtenance as that term is used in Me. Rev. Stat. 14, 8104-A(2) and, therefore, that no exception to governmental immunity applied. The Supreme Judicial Court affirmed, holding that the superior court correctly determined that the University was entitled to summary judgment. View "Klein v. University of Maine System" on Justia Law