Justia Maine Supreme Court Opinion Summaries

Christian D., the father of a three-year-old child, appealed a judgment by the District Court (South Paris) that terminated his parental rights. The court found him unfit as a parent and determined that termination was in the child's best interest. The father argued that the court abused its discretion by not making specific findings of fact to support its decision and by not adequately considering a permanency guardianship as an alternative to termination.The District Court found that the father was unfit based on three grounds under 22 M.R.S. § 4055(1)(B)(2)(b)(i), (ii), and (iv). The court noted that the child had been in the custody of the Department of Health and Human Services (DHHS) for 26 of his 35 months and that the child needed permanency, which the father could not provide in a timely manner. The child had been living in a stable and nurturing foster home with his maternal grandparents, who were willing to adopt him.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's judgment. The court held that the District Court properly exercised its discretion and that the record supported the findings that termination of the father's parental rights and adoption were in the child's best interest. The court also rejected the father's argument that Rule 52(a) precluded reliance on inferences or implicit findings, noting that the trial court's findings were sufficient to support the judgment. The court emphasized the importance of permanency for the child and found that the father's inability to provide a stable environment justified the termination of his parental rights. View "In re Child of Christian D." on Justia Law

Michael Zani and Peter Zani, sons of Patricia M. Spofford, appealed a summary judgment from the Lincoln County Probate Court. The court found no genuine issue of material fact regarding Spofford’s testamentary capacity when she executed her will on March 1, 2018. The Zanis argued that there was a genuine issue concerning her testamentary capacity, despite having no direct evidence from the date the will was executed. They contended that other evidence from before and after the will's execution cast doubt on her capacity.The Probate Court granted summary judgment, concluding that Spofford had the requisite testamentary capacity. The court relied on videos of the will’s execution, which showed Spofford understood the nature of her actions, knew the extent of her estate, identified her family members, and expressed clear wishes about her estate's disposition. Additionally, affidavits from Spofford’s attorney and a witness, as well as testimony from her primary care physician, supported the conclusion that she was competent on the day she executed her will.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Probate Court’s judgment. The court found that the evidence presented by the Zanis, including incidents and medical notes from before and after the will's execution, was too remote to create a genuine dispute of material fact regarding Spofford’s testamentary capacity on March 1, 2018. The court also noted that a diagnosis of dementia or Alzheimer’s disease does not preclude testamentary capacity and that being under guardianship or conservatorship does not automatically negate the ability to execute a will. The judgment of the Probate Court was affirmed. View "Estate of Spofford" on Justia Law

Keara M. Bernier was convicted of aggravated assault after a jury trial in Aroostook County. The incident occurred on June 6, 2022, when Bernier struck the victim, her partner, in the head with an aluminum baseball bat during an argument at their shared home. The victim did not seek medical attention immediately but reported the incident to the police the next day. Bernier was indicted in July 2022 and, after a jury trial in September 2023, was found guilty and sentenced to seven years in prison, with all but six months suspended, and three years of probation.At trial, Bernier argued that the trial judge's comments during her testimony questioned her veracity, thus denying her a fair trial. She also contended that the court erred in its jury instructions regarding the use of deadly force in self-defense, specifically that it failed to instruct the jury that she had no duty to retreat if she was in her dwelling place and was not the initial aggressor.The Maine Supreme Judicial Court reviewed the case. The court found no obvious error in the trial judge's comments, determining that the judge's instructions to Bernier to answer questions truthfully were aimed at keeping her focused and were not indicative of bias. However, the court agreed with Bernier that the jury instructions on the use of deadly force were incomplete. The instructions failed to include the statutory exception that Bernier had no duty to retreat if she was in her dwelling place and was not the initial aggressor.The Maine Supreme Judicial Court vacated Bernier's conviction and remanded the case for a new trial, holding that the omission of the dwelling-place exception in the jury instructions constituted an obvious error affecting Bernier's substantial rights. View "State of Maine v. Bernier" on Justia Law

Charles S. Keegan filed a complaint against the Estate of Phyllis C. Bradbury and its representatives, as well as Craig J. and Melissa M. Holmes, alleging that he had a right of first refusal to purchase a property at 1 Lower High Street in Eastport. Keegan based his claim on a purchase and sale agreement for a different property, which he argued included a provision granting him this right. The agreement's Section 26 stated that the buyer "would like the Right of First Refusal on the sale of abutting lot if ever sold."The Superior Court of Washington County dismissed Keegan's complaint for failure to state a claim upon which relief could be granted. The court found that the language in Section 26 was precatory and did not create an enforceable right of first refusal. Keegan's initial appeal was dismissed as interlocutory. Subsequently, the Holmeses filed a motion to dismiss, which the Superior Court granted, relying on the previous dismissal as the law of the case. This resulted in a final judgment against Keegan, who then appealed.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Superior Court's judgment. The court held that the language in Section 26 of the purchase and sale agreement was clear and did not create an enforceable right of first refusal. The phrase "would like" was deemed precatory, expressing a wish rather than a binding obligation. Consequently, Keegan's complaint failed to state a claim upon which relief could be granted, as there was no enforceable right of first refusal, no breach of contract, and no basis for rescission or equitable relief. View "Keegan v. Estate of Bradfury" on Justia Law

Aubrey Armstrong was convicted of felony murder and robbery following a bench trial in July 2018. He was sentenced to thirty years for felony murder and a concurrent thirty-year term for robbery, with all but twenty-nine years suspended and four years of probation. Armstrong appealed, and the Maine Supreme Judicial Court found that his simultaneous convictions for felony murder and robbery violated the double jeopardy clause. The court vacated the judgment and remanded for further proceedings to merge the counts and impose a sentence on the merged count. On remand, the trial court dismissed the robbery count and resentenced Armstrong to thirty years for the merged count. Armstrong's subsequent appeals were denied.Armstrong filed his first petition for post-conviction review on April 10, 2023, which was summarily dismissed for failing to allege any cognizable grounds for relief. He then filed a second petition on June 29, 2023, alleging ineffective assistance of counsel and prosecutorial misconduct. The PCR court dismissed this petition as untimely, as it was filed beyond the one-year deadline. Armstrong appealed and sought a certificate of probable cause, which was granted by the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the case and concluded that Armstrong waived his argument regarding the timeliness of his petition by not raising it in the lower court. The court vacated the order granting a certificate of probable cause and dismissed the appeal as improvidently granted. The court did not address whether the doctrine of equitable tolling applies to petitions for post-conviction review, as Armstrong failed to present this argument to the PCR court. View "Armstrong v. State of Maine" on Justia Law

Alrig USA Acquisitions LLC, a commercial real estate developer, entered into a purchase and sale agreement with MBD Realty LLC for a property in Portland. MBD was aware that the City of Portland planned to redevelop the area, which would involve condemning part of the property, but did not disclose this to Alrig. The agreement included clauses allowing Alrig to terminate the agreement and receive a refund of its deposit under certain conditions, including eminent domain. Alrig extended the inspection period multiple times, paying additional deposits, and eventually waived its due diligence and title review contingencies, making the deposit nonrefundable except in the event of MBD’s default. Alrig later learned of the redevelopment plans and terminated the agreement, seeking a refund of the deposit, which MBD refused.The Superior Court (Cumberland County) granted MBD’s motion to dismiss Alrig’s complaint for breach of contract and fraud, concluding that MBD had no duty to disclose the redevelopment plans. Alrig appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the Superior Court’s judgment. The court held that the amendment to the agreement unambiguously made the deposit nonrefundable except in the event of MBD’s default, and thus Alrig’s contract claim failed. Additionally, the court found that MBD did not actively conceal the City’s planned condemnation, and there was no special relationship imposing a duty to disclose. Therefore, Alrig’s fraud claim also failed as a matter of law. The court concluded that Alrig was not entitled to relief under any set of facts that might be proven in support of its claims. View "Alrig USA Acquisitions LLC. v. MBD Realty LLC" on Justia Law

The case involves Eastern Maine Medical Center and eight other Maine hospitals (the Hospitals) who filed a 509-page complaint against various businesses and individuals (the Opioid Sellers) involved in the marketing and distribution of prescription opioids. The Hospitals alleged that the Opioid Sellers created illegitimate demand for opioids and unlawfully increased supply, leading to an opioid epidemic that caused the Hospitals to incur high costs for treating patients with opioid misuse, addiction, and dependency, with only partial reimbursement from insurance.The Business and Consumer Docket (Duddy, J.) dismissed the Hospitals' complaint. The court found that the complaint did not comply with the requirement for a "short and plain statement" of the claim but chose to dismiss it based on the legal insufficiency of the claims. The court concluded that the Hospitals could not recover under any of their legal theories, including negligence, public nuisance, unjust enrichment, fraud and negligent misrepresentation, fraudulent concealment, and civil conspiracy. The court also denied the Hospitals' request for leave to amend their complaint.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's dismissal. The court held that the Hospitals' claims were legally insufficient. Specifically, the court found that the Hospitals did not have a direct negligence claim, as they did not suffer harm directly caused by the Opioid Sellers. The fraud and misrepresentation claims failed due to lack of reliance by the Hospitals on the Opioid Sellers' misrepresentations. The unjust enrichment claim was dismissed because the Hospitals did not confer a benefit on the Opioid Sellers. The public nuisance claim failed as the Hospitals did not suffer a special injury different in kind from the public. Lastly, the civil conspiracy claim was dismissed as it required an underlying tort, which was not present. The court concluded that the deficiencies in the complaint could not be remedied by amendment. View "Eastern Maine Medical Center v. Walgreen Co." on Justia Law

Julio Cesar Hernandez-Rodriguez was convicted of two drug offenses after a trial court denied his motion to suppress statements made to Maine Drug Enforcement Agency (MDEA) agents. Hernandez-Rodriguez argued that his statements to one agent should be suppressed because he was subject to unwarned custodial interrogation and that his statements to another agent should be suppressed due to his limited English proficiency, which he claimed prevented him from making a knowing and voluntary waiver of his rights.The trial court found that Hernandez-Rodriguez was in custody during his interactions with the agents and that he had not waived his Miranda rights while speaking with the first agent. However, the court concluded that his statements to the first agent were admissible because they were not the product of interrogation. The court also found that Hernandez-Rodriguez had knowingly and voluntarily waived his Miranda rights when speaking with the second agent, despite his limited English proficiency. Hernandez-Rodriguez entered a conditional guilty plea, preserving his right to appeal the suppression rulings.The Maine Supreme Judicial Court reviewed the case and determined that the trial court erred in not suppressing Hernandez-Rodriguez’s statement identifying a substance as cocaine in response to the first agent’s question, as it was the product of custodial interrogation. However, the court upheld the trial court’s finding that Hernandez-Rodriguez had validly waived his Miranda rights when speaking with the second agent. Given the error in admitting the statement about the cocaine, the court vacated the judgment and remanded the case, allowing Hernandez-Rodriguez the opportunity to withdraw his plea. View "State of Maine v. Hernandez-Rodriguez" on Justia Law

James M. Day appealed a decision by the Town of Hiram Planning Board, which granted Brian and Sarah Schnell a conditional use permit to construct a microbrewery on a property in the Town’s Residential District. Day argued that the Board erred in its interpretation of the "need" factor required by the Town of Hiram’s Zoning Ordinance, which mandates consideration of the necessity of a particular location for the proposed use.The Superior Court (Oxford County) initially remanded the case to the Planning Board for findings of fact. After the Board reaffirmed its decision with additional findings, Day appealed again. The Superior Court then affirmed the Board’s decision, leading Day to appeal to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the Planning Board’s decision directly. The Court found that the Board had misinterpreted the "need" factor by focusing on the Schnells' lack of alternative properties rather than the community's need for the proposed microbrewery at that specific location. The Court clarified that the "need" factor should consider the community's need for the proposed use in the proposed location, not the applicant's personal need for that location.The Court vacated the Superior Court’s judgment and remanded the case to the Town of Hiram Planning Board for further proceedings consistent with its opinion. The Board may reopen the record to allow for additional evidence relevant to the correct interpretation of the "need" factor. View "Day v. Town of Hiram" on Justia Law

Richard W. Kelley was convicted of aggravated trafficking of scheduled drugs after a stop and search of a friend's vehicle in which he was a passenger. Law enforcement conducted the search as part of an investigation into the vehicle's owner for drug trafficking, using a search warrant and two tracking warrants to monitor the vehicle's location. Kelley moved to suppress the evidence obtained through the warrants, arguing that he had a reasonable expectation of privacy in the vehicle.The trial court (Penobscot County, A. Murray, J.) denied Kelley's motion to suppress on the grounds that he lacked standing to challenge the search. Kelley argued that the court should not have addressed his standing because the State had stipulated that he had a reasonable expectation of privacy in the vehicle. However, the court concluded that standing is a threshold issue that must be addressed regardless of the State's stipulation. Kelley was subsequently convicted based on his conditional guilty plea.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the State's stipulation regarding Kelley's standing was not binding on the court. The court further held that Kelley lacked a reasonable expectation of privacy in the vehicle, as he did not have a property or possessory interest in it, nor did he have an interest in the property seized. Therefore, Kelley did not have standing to challenge the search warrants. The judgment of conviction was affirmed. View "State of Maine v. Kelley" on Justia Law