Justia Maine Supreme Court Opinion Summaries

A man was observed by a police officer in an area behind several businesses that was marked with no-trespassing signs and known for illicit drug activity. When the officer approached, the man acted suspiciously, attempted to walk away, and appeared to conceal something in his pocket. The officer, who recognized the man from previous encounters near drug houses, learned that the man was subject to bail conditions permitting searches based on articulable suspicion of drug use or possession. Upon searching him, the officer found fentanyl and cocaine, as well as drug paraphernalia and cash.The Superior Court (Penobscot County) denied the defendant’s motion to suppress the evidence, finding that the officer had reasonable suspicion to stop and search him. At trial, the court allowed expert testimony from a Maine Drug Enforcement Agency commander regarding drug prices, after offering the defense a continuance to address late disclosure, which the defense declined. The jury convicted the defendant of aggravated trafficking in fentanyl and unlawful trafficking in cocaine. The court declined to instruct the jury on unlawful possession as a lesser included offense for the fentanyl charge but did so for the cocaine charge. The defendant was sentenced to seven years (with four suspended) for aggravated trafficking, four years concurrent for cocaine trafficking, and thirty days for violating a condition of release, with forfeiture ordered.On appeal, the Maine Supreme Judicial Court affirmed the judgment. The Court held that the officer had reasonable suspicion for both the stop and the search, the trial court did not abuse its discretion in admitting the expert testimony or in its handling of the discovery issue, and any error in failing to instruct on a lesser included offense for the fentanyl charge was harmless. The Court also found no error in the sentencing analysis. View "State of Maine v. Schlosser" on Justia Law

Law enforcement stopped a vehicle driven by the defendant on December 1, 2021, and discovered drug paraphernalia, cash, and various illegal drugs in the car and on her person. The defendant admitted ownership of the drugs. On January 20, 2022, after she used a counterfeit bill to post bail for another individual, police searched her vehicle again and found large quantities of fentanyl, methamphetamine, and cocaine, as well as drug packaging materials and a firearm. The following day, a search of her home uncovered more drugs, cash, firearms, and evidence of drug sales. In total, authorities seized significant amounts of fentanyl, methamphetamine, and cocaine. The defendant was indicted on three counts of aggravated trafficking of scheduled drugs and one count of unlawful possession, with the State aggregating the drug quantities across the incidents as part of a continuing scheme.The case was tried before a jury in the Penobscot County Unified Criminal Docket. During closing arguments, defense counsel suggested that some of the drugs belonged to a passenger, referencing evidence that the passenger brought a Walmart bag containing drugs into the car. The State objected, claiming this was not in evidence, and the trial court sustained the objection. The jury found the defendant guilty on all counts, and the court entered judgment and ordered forfeiture of property. The defendant appealed, arguing that the court’s ruling during closing argument improperly commented on the evidence and infringed on her rights.The Maine Supreme Judicial Court held that the trial court erred in sustaining the State’s objection, as there was evidence supporting the defense’s argument. However, the Court concluded that the error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt, the opportunity for the defense to present its theory, and the court’s instructions to the jury. The judgment of conviction was affirmed. View "State of Maine v. Quirion" on Justia Law

Lorri Bosse, a truck driver with a long work history, was employed by Sargent Corporation, where she typically worked fifty to seventy hours per week but was laid off each winter due to company policy, not by her own choice. Bosse would have preferred to work year-round, and some other drivers at Sargent did so. In 2015, she suffered a gradual work injury and filed for workers’ compensation benefits, having worked thirty out of the fifty-two weeks preceding her injury. Her annual earnings at Sargent were consistently lower than the annualized amount that would result from the statutory calculation method used by the administrative law judge (ALJ).After an evidentiary hearing, the ALJ awarded Bosse benefits and calculated her average weekly wage (AWW) using the method in 39-A M.R.S. § 102(4)(B), which applies when an employee has worked fewer than 200 full working days in the year before injury. Sargent Corporation argued that this method produced an inflated AWW compared to Bosse’s actual earnings and that the fallback method in paragraph D should be used instead. The Workers’ Compensation Board Appellate Division remanded for further factual findings but ultimately affirmed the ALJ’s use of paragraph B, finding it fair and reasonable under the circumstances.The Maine Supreme Judicial Court reviewed the case and affirmed the Appellate Division’s judgment. The Court held that, for employees who work more than 26 weeks but fewer than 200 days in the year before injury, paragraph B is generally the appropriate method for calculating AWW. The fallback method in paragraph D should only be used in exceptional circumstances where applying paragraph B would be unreasonable or unfair, such as when the employee’s part-time work was voluntary or the calculated AWW is grossly inflated for reasons not tied to future earning capacity. The Court found no error in the Board’s application of paragraph B in Bosse’s case. View "Bosse v. Sargent Corporation" on Justia Law

A married couple with three minor children separated after more than a decade together, with the wife returning to Maine with the children and the husband remaining in the marital home in Atlanta. The wife, who had been the primary homemaker, filed for divorce, seeking division of property, spousal support, child support, and attorney fees. The husband, who had a significantly higher income, continued to pay the mortgage on the marital home, which had substantial equity.The Maine District Court in Calais held a contested hearing and entered a divorce judgment. The court awarded shared parental rights, primary physical residence of the children to the wife, and divided the marital property by awarding the home to the husband but granting the wife half the equity. The husband was ordered to pay spousal and child support, as well as the wife’s attorney fees. The husband filed post-judgment motions seeking clarification and amendment, particularly regarding the calculation of spousal support and attorney fees. The court reaffirmed its findings, including imputing minimum-wage income to the wife and finding the attorney fee award reasonable. The husband then appealed.The Maine Supreme Judicial Court reviewed the case and found a clerical error in the District Court’s property distribution table, which double-counted the equity in the marital home. This error potentially affected the determinations of spousal support and attorney fees. The Supreme Judicial Court vacated the judgment as to the property distribution calculations and remanded for correction and reconsideration of spousal support and attorney fees in light of the corrected figures. The judgment was affirmed in all other respects. The Court denied the wife’s request for appellate attorney fees as sanctions but allowed her to seek such fees in the trial court. View "Newman v. Riser" on Justia Law

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