Justia Maine Supreme Court Opinion Summaries

Jason Servil was charged with murder and aggravated assault after he fatally stabbed his ex-girlfriend and attacked a man accompanying her with a crowbar. Following his indictment, Servil entered into a plea agreement with the State, capping his potential sentence for murder at forty-five years, though he was permitted to argue for a lesser term. He pleaded guilty to both charges, and the court scheduled a sentencing hearing, during which it heard statements from the victims’ family members, a mental health professional, Servil’s relatives, and Servil himself.The Somerset County Unified Criminal Docket accepted Servil’s guilty pleas and, after the sentencing hearing, imposed a forty-five-year sentence for murder and a concurrent ten-year sentence for aggravated assault, along with restitution. During sentencing, the court conducted the required two-step analysis for murder convictions, considering aggravating and mitigating factors. Notably, the court independently obtained and read the victim’s obituary into the record as part of its analysis of the subjective effect on the victim. Servil appealed, arguing that the court’s use of the obituary constituted an abuse of discretion and violated his rights. The Sentence Review Panel granted his application for leave to appeal.The Maine Supreme Judicial Court reviewed the case and determined that the sentencing court abused its discretion by relying on information from the victim’s obituary, which it had obtained independently and was not disclosed to the defense prior to sentencing. The Supreme Judicial Court held that this reliance on extrajudicial information was impermissible and that the error was not harmless. As a result, the Court vacated Servil’s sentences and remanded the case for resentencing before a different judge. View "State of Maine v. Servil" on Justia Law

The case concerns Neil T. MacLean, who was convicted by a jury of attempted murder and two counts of arson after he set fire to his bed in an apartment building where he and his wife lived, along with other residents. On the night of the incident, MacLean had been drinking and was aware that his wife was sleeping nearby. After the fire started, his wife called 9-1-1, and police officers evacuated her and eventually removed MacLean from the burning apartment. No fatalities occurred, but two officers suffered smoke inhalation. MacLean later admitted to an investigator that he intended to kill himself, his wife, and the other residents.Following the incident, MacLean was charged and underwent mental health evaluations. He pleaded not guilty, and after unsuccessful settlement discussions and further mental health examination, the case proceeded to a jury trial in the Somerset County Unified Criminal Docket. The jury found him guilty on all counts. The trial court sentenced him to twenty-five years, with all but fifteen years suspended, for attempted murder, and concurrent fifteen-year sentences for the arson convictions, plus probation. MacLean appealed, raising issues regarding jury instructions, evidentiary rulings, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court did not commit obvious error by failing to instruct the jury on the defense of abnormal condition of the mind, as the evidence did not warrant such an instruction. The court also found that any error in admitting testimony from MacLean’s wife was harmless, and that the trial court did not abuse its discretion in denying a mistrial or curative instruction after the prosecutor referred to the wife as a hostile witness. However, the court agreed with both parties that the convictions should have been merged for sentencing, so it vacated the sentence and remanded for resentencing, while affirming the judgment of conviction in all other respects. View "State of Maine v. MacLean" on Justia Law

The defendant was convicted after a bench trial of several offenses, including attempted murder, domestic violence aggravated assault, domestic violence criminal threatening, assault on an officer, and violating a condition of release. The convictions arose from an incident in which the defendant, following a period of repeated contact with his former partner, attacked her in a hotel parking lot. The attack involved strangulation, threats to kill, and physical violence, resulting in significant injuries to the victim. Bystanders, including a hotel clerk and a van driver, intervened, and police officers ultimately subdued and arrested the defendant after a struggle in which an officer was bitten and his firearm was nearly taken.The Kennebec County Unified Criminal Docket (Murphy, J.) found the defendant guilty of the charged offenses. At sentencing, the court imposed a thirty-year sentence for attempted murder, with all but eighteen years suspended and four years of probation, and additional sentences for the other convictions. In determining the sentence for attempted murder, the court considered the brutality and persistence of the attack as aggravating factors, as well as the defendant’s lack of criminal history and acceptance of responsibility as mitigating factors. The court declined to treat the defendant’s “blind jealous rage” as a mitigating factor, finding it was not a biologically based mental illness.On appeal, the Maine Supreme Judicial Court reviewed two arguments: that the trial court violated the Eighth Amendment by not considering the defendant’s “blind rage” as a mitigating factor, and that the court erred in finding as an aggravating factor that the defendant assaulted the hotel clerk. The Supreme Judicial Court held that the Eighth Amendment does not require a sentencing court in a noncapital case to consider unprovoked “blind rage” as a mitigating factor. However, the Court found plain error in the trial court’s reliance on an unsupported finding that the defendant assaulted the hotel clerk as an aggravating factor. The judgment of sentence for attempted murder was vacated and the case remanded for resentencing. View "State of Maine v. Goncalves" on Justia Law

Deborah A. Chatfield filed for divorce from Frederick H. Chatfield Jr. on July 14, 2021. Frederick initially had legal representation, but his attorney withdrew in December 2021, leaving him to represent himself. A final hearing was held on August 23, 2024, which Frederick did not attend. The court granted the divorce and classified certain real estate in Rockport as marital property, ordering its sale. Frederick did not appeal the divorce judgment or request further findings of fact.Frederick later retained counsel and filed a motion for relief from judgment under M.R. Civ. P. 60(b), arguing that the property was nonmarital, the court lacked jurisdiction, and Deborah's belief that the property was marital was a mistake. The District Court (Rockland) denied the motion, finding that Frederick had not protected his interests during the original proceedings and had not provided justification for his absence. The court also found no credible evidence to support Frederick's claims.The Estate of Frederick H. Chatfield Jr. appealed the denial to the Maine Supreme Judicial Court. The court reviewed the denial for abuse of discretion, considering whether the lower court's findings were supported by the record, whether the court understood the applicable law, and whether the court's decisions were reasonable. The Supreme Judicial Court affirmed the lower court's decision, finding no abuse of discretion or clear error. The court noted that Frederick failed to protect his interests by not attending the hearing, not filing for further findings, and not appealing the original judgment. The court also found that the lower court had jurisdiction over the property and that Frederick did not meet the burden of proof required for relief under Rule 60(b). View "Chatfield v. Estate of Chatfield" on Justia Law

Katrina M. Welch filed a complaint seeking de facto parentage of the biological child of her former partner, Naomi R. Chavaree. Welch claimed she had undertaken a permanent, committed parental role, established a bonded relationship with the child, and that it was in the child's best interest to continue their relationship. Welch's affidavit detailed her involvement during Chavaree's pregnancy, the child's birth, and their life together until their separation. She asserted that she played an active role in the child's life, including co-parenting after their separation.The District Court (Biddeford, Sutton, J.) dismissed Welch's complaint for lack of standing, determining that Welch had not made a prima facie showing of the statutory requirements for de facto parentage. The court concluded that Welch's affidavit did not demonstrate that her relationship with the child was fostered or supported by Chavaree or that both parties understood or accepted Welch as a parent. Welch's request for an expedited hearing was also denied as moot.The Maine Supreme Judicial Court reviewed the case and found that the District Court abused its discretion by not holding a hearing to resolve disputed facts material to the issue of standing. The Supreme Judicial Court noted that Welch's affidavit, if accepted as true, could support a finding of standing and that there were bona fide issues of material fact regarding Welch's role and Chavaree's acceptance of that role. The court emphasized that a hearing was necessary to assess the credibility of the parties' conflicting affidavits.The Maine Supreme Judicial Court vacated the District Court's dismissal and remanded the case for further proceedings, including a hearing to determine the disputed facts related to Welch's standing to seek de facto parentage. View "Welch v. Chavaree" on Justia Law

Carol Cutting filed a medical malpractice lawsuit against Down East Orthopedic Associates, P.A., based on treatment she received in 2013. Cutting alleged that a doctor at Down East treated her shoulder improperly and failed to obtain informed consent, particularly regarding how her Tourette’s syndrome might affect the surgery. She also claimed the doctor falsified her medical records. A prelitigation screening panel found unanimously against Cutting, determining that the doctor’s conduct did not deviate from the standard of care.The Superior Court (Penobscot County) admitted the panel’s finding into evidence at trial. The jury found that Down East was not negligent. Cutting challenged the admission of the panel’s finding, arguing it was biased and violated her due process rights. She also contested the court’s judgment as a matter of law on her claim for punitive damages, arguing that the court erred in its decision.The Maine Supreme Judicial Court reviewed the case. The court held that the trial court did not abuse its discretion in admitting the panel’s finding. The court noted that the panel’s offer to decide the case based on written records, if both parties agreed, did not demonstrate bias, especially since the offer was declined and a full hearing was held. The court also found that the trial court provided the jury with the necessary instructions to contextualize the panel’s finding, preserving Cutting’s right to a jury trial.Regarding punitive damages, the court held that any error in granting Down East’s motion for judgment as a matter of law was harmless. Since the jury found no negligence, they could not award any damages, including punitive damages. Therefore, the court affirmed the judgment in favor of Down East Orthopedic Associates, P.A. View "Cutting v. Down East Orthopedic Associates, P.A." on Justia Law

Kyle M. Fitzgerald was stopped by Maine State Police on Interstate 295 for not wearing a seatbelt and driving significantly below the speed limit. During the stop, Fitzgerald and her passengers gave inconsistent and confusing answers about their destination and how long they had known each other. One passenger was particularly anxious, another was standoffish, and a third pretended to be asleep. The police officer, Trooper Young, requested a drug detection dog, which arrived seventy-seven minutes after the stop began. The dog indicated the presence of drugs, leading to a search that uncovered a substantial quantity of illegal drugs.The trial court (Cumberland County) granted Fitzgerald’s motion to suppress the evidence obtained from the search, finding that the officers lacked probable cause. The court determined that the reasonable suspicion justifying the initial stop had been resolved well before the dog arrived, and there was no reasonable suspicion of illegal drug activity to justify prolonging the detention.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the duration of Fitzgerald’s detention exceeded the constitutional limit once the officer confirmed the identity of one of the passengers, which was thirty-four minutes before the drug detection dog arrived. The court concluded that the officer’s suspicion of illegal drug activity was based on a general hunch rather than an articulable and objectively reasonable suspicion. Therefore, the prolonged detention violated the Fourth Amendment, and the evidence obtained from the search was rightly suppressed. View "State v. Fitzgerald" on Justia Law

Snakeroot Solar, LLC, sought a good-cause exemption from the Public Utilities Commission (PUC) to extend the deadline for its photovoltaic generating facility in Pittsfield to reach commercial operation and participate in Maine’s net energy billing (NEB) program. The facility needed to be operational by December 31, 2024, but delays in the interconnection process and the time required for grid upgrades made this deadline unachievable. Snakeroot argued that these delays were outside its control and warranted an exemption.The PUC denied Snakeroot’s petition, finding that the delays were inherent to the interconnection process and not external. The PUC noted that the cluster study process, which took slightly longer than average, and the time required for grid upgrades were typical and did not constitute external delays. Snakeroot appealed, arguing that the PUC misinterpreted the statute and that the delays were indeed external and beyond its control.The Maine Supreme Judicial Court reviewed the case and upheld the PUC’s decision. The Court found that the PUC’s interpretation of the statute was reasonable and aligned with the legislative intent to limit the number of projects eligible for the NEB program to control electricity rates. The Court also determined that the PUC’s findings were supported by substantial evidence, including the typical duration of cluster studies and the standard lead times for equipment procurement. The Court concluded that the PUC did not abuse its discretion in denying the exemption, as the delays experienced by Snakeroot were part of the normal interconnection process and not extraordinary. View "Snakeroot Solar, LLC v. Public Utilities Commission" on Justia Law

Alex Titcomb and four other registered Maine voters challenged the wording of a ballot question for citizen-initiated legislation that would amend Maine voting laws. They argued that the question did not meet statutory requirements to be understandable and not misleading to a reasonable voter. The proposed legislation included various changes to election laws, such as requiring photo ID for voting, ending ongoing absentee voting for seniors and people with disabilities, and other modifications.The Superior Court (Cumberland County) affirmed the Secretary of State’s decision on the wording of the ballot question. The court found that the language used in the question was understandable and not misleading. Titcomb appealed this decision, arguing that the question improperly singled out the effect on seniors and people with disabilities and used confusing terms.The Maine Supreme Judicial Court reviewed the case and upheld the Superior Court’s judgment. The court concluded that the ballot question was not misleading and was understandable to a reasonable voter. The court noted that the language used in the question accurately reflected the proposed legislation and that the terms used were clear to an informed voter. The court also found that the length of the question, while longer than usual, was necessary to convey the various changes proposed in the legislation. The judgment of the Superior Court was affirmed. View "Titcomb v. Secretary of State" on Justia Law

Pamela J. (Tower) Weinle appealed a divorce judgment from the District Court (Skowhegan), which divided marital property and awarded Alan R. Tower spousal support and attorney fees. Weinle contested the spousal support, property distribution, and attorney fees. Tower died after the judgment and during the appeal process.The District Court awarded Tower $2,000 per month in general spousal support, $500 per month in reimbursement spousal support, and $12,325 in attorney fees. The court found that Weinle had engaged in economic misconduct by purchasing and selling property without Tower's knowledge and failing to comply with discovery obligations, which increased litigation costs. The court also noted that Weinle had a substantial income and financial resources, while Tower had limited income and poor health.The Maine Supreme Judicial Court overruled its previous decision in Panter v. Panter, which required dismissal of an appeal if a party died during its pendency. The court held that the death of a party does not moot the appeal regarding property rights. The court affirmed the District Court's judgment, finding no error in the spousal support award, property distribution, or attorney fees. The court noted that the spousal support obligation ceased upon Tower's death, as the divorce judgment did not specify that the support survived the death of either party. View "Weinle v. Estate of Tower" on Justia Law