Justia Maine Supreme Court Opinion Summaries

In these cases concerning property tax abatement requests the Supreme Judicial Court affirmed two decisions of the superior court vacating a decision denying requests for abatement and granting a petition for judicial review of an adverse decision concerning another request for a tax abatement, holding that the superior court did not err.This consolidated appeal concerned property tax abatement requests made by the Roque Island Gardner Homestead Corporation (RIGHC). The superior court vacated a decision of the Board of Appeals (BOA) of the Town of Jonesport denying RIGHC's requests for abatement concerning three tax years and remanded the matter for the BOA to make an independent determination of the property's fair market value. The court also granted judicial review as to the State Board of Property Tax Review's adverse decision concerning RIGHC's request for another tax year abatement and directed the Town to grant the abatement request. The Supreme Judicial Court affirmed both decisions, holding that the superior court did not err. View "Roque Island Gardner Homestead Corp. v. Town of Jonesport" on Justia Law

In this consolidated appeal regarding collection actions by a debt buyer, the Supreme Judicial Court vacated the judgments that the district court entered in favor of Portfolio Recovery Associates, LLC, holding that the court's factual findings underlying the admission of certain challenged records were erroneous.When the trial court decided these credit card debt collection matters Supreme Judicial Court jurisprudence contained conflicting interpretations of Me. R. Evid. 803(6) with regard to the admission of integrated business records. The trial court admitted the records in accordance with the predominant evidentiary standards at the time. In Bank of New York Mellon v. Shone, 239 A.3d 671 (Me. 2020), however, the Supreme Court clarified the proper approach for evaluating the sufficiency of the foundation laid for the admission of integrated business records. In the instant case, the Supreme Judicial Court held that because the parties developed their records with a different evidentiary standard in mind, fairness required that the matters be remanded for further proceedings, including potentially reopening the record to allow further evidence or to take new evidence. View "Portfolio Recovery Associates, LLC v. Casey Clougherty Portfolio Recovery Associates, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the Department of Public Safety's denial of Appellant's application for a professional investigator license, holding that Appellant's First Amendment rights were not violated by the application of statutory competency standards to his conduct on social media.The Department denied Appellant's application based on comments and posts that he had made on social media using an account bearing the name of his out-of-state private investigation business concerning a police lieutenant. The Supreme Judicial Court affirmed the circuit court's affirmation of the Department's decision, holding (1) intermediate scrutiny applies to the Department's application of the licensing statutes to Appellant's application; (2) the Department did not err in its findings; and (3) the Department's application of the licensing standards to Appellant did not violate the First Amendment. View "Gray v. Department of Public Safety" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of the depraved indifference murder of her daughter and sentence of forty-eight years in prison, holding that Defendant's claims of error were unavailing.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress the statements she made to investigators on the day of and the day after her daughter's death; (2) the trial court did not abuse its discretion by denying Defendant's request for a mistrial; (3) the court did not err by declining Defendant's requests for jury instructions regarding accomplice liability and duress; and (4) the court acted within its discretion in arriving at Defendant's sentence. View "State v. Carrillo" on Justia Law

The Supreme Judicial Court vacated the decision of the Appellate Division of the Workers' Compensation Board (WCB) affirming the decision of the WCB ALJ denying Appellant's petition for review of incapacity benefits paid by Hydraulic Hose & Assemblies, LLC, through its insurer, The Hanover Insurance Group, because the statute of had expired, holding that the claim was timely.Appellant filed a petition for review of incapacity, claiming that he was entitled to total incapacity benefits. The ALJ denied the petition, concluding that the six-year statutory limitation period had expired and that Appellant's receipt of Social Security benefits did not toll the statute of limitations. On appeal, Appellant argued that the receipt of his Social Security benefits under the circumstances tolled the statute of limitations. The Supreme Judicial Court agreed, holding (1) offsetting Social Security old-age insurance benefits must be treated as primary payments of workers' compensation; and (2) the "date of the most recent payment" under Me. Rev. Stat. 39-A, 306 is the date of most recent payment of offsetting Social Security old-age insurance benefits. View "Charest v. Hydraulic Hose & Assemblies, LLC" on Justia Law

The Supreme Judicial Court affirmed the superior court's entry of summary judgment in favor of Twin Rivers Paper Company, LLC on Plaintiff's claim brought under the Maine Whistleblowers' Protection Act (WPA), Me. Rev. Stat. 26, 831-340, holding that the superior court did not err.In granting summary judgment for Twin Rivers, the superior court concluded that Plaintiff's claim was preempted by the combined effect of section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), and section 837 of the WPA. The Supreme Judicial Court affirmed, holding that Plaintiff's claim was preempted by the operation of LMRA section 301 in combination with WPA section 837. View "Nadeau v. Twin Rivers Paper Company, LLC" on Justia Law

The Supreme Judicial Court affirmed the dispositional order imposed after an adjudication that juvenile Timothy Silva committed manslaughter, holding that the court did not err in committing him to detention.Silva was sixteen years old when he lost control of a vehicle and caused the death of three passengers and serious injuries to a fourth. The juvenile court adjudicated Silva to have committed one count of manslaughter and committed him to Long Creek Youth Development Center for an undetermined period of up Silva's twenty-first birthday. The Supreme Judicial Court affirmed, holding that the court's disposition was neither error nor an abuse of discretion. View "State v. Silva" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Business and Consumer Docket in favor of JJ Cars, LLC and John Mokarzel on H&B Realty, LLC's complaint for breach of contract, holding that there was no error in the court's judgment.The lower court determined that H&B breached the lease in this case by unreasonably withholding consent to a proposed sublease. On appeal, H&B argued that the court erred in applying the affirmative defenses, as pleaded by JJ Cars and Mokarzel, of breach of contract and failure to mitigate damages. The Supreme Judicial Court affirmed, holding that there was competent record evidence to support the court's finding that H&B materially breached the lease by refusing to consent to sublet the property. View "H&B Realty, LLC v. JJ Cars, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Appellant's complaint for lack of subject matter jurisdiction, holding that the superior court did not err in determining that Appellant's dispute with Regina Petit and the Passamaquoddy Tribe was an "internal tribal matter."After Appellant contacted the Chief of Police for the Passamaquoddy Tribe and caused Appellant to be served with a no-trespass notice, Appellant filed a complaint against Petit and the Tribe. The superior court granted Petit and the Tribe's motion to dismiss for lack of subject matter jurisdiction, concluding that the dispute involved an "internal tribal matter." The Supreme Judicial Court affirmed, holding that the most appropriate forum for this case was the tribal court. View "Moyant v. Petit" on Justia Law

The Supreme Judicial Court affirmed Defendant's judgment of conviction for intentional or knowing murder, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that the trial court erred in refusing to give a jury instruction on the affirmative defense of adequate provocation, erroneously denied his motion to suppress multiple confessions, and abuse its discretion in denying his motion to recuse the presiding justice. The Supreme Judicial Court affirmed, holding that the trial court (1) correctly determined that the jury instruction for adequate provocation was not generated by the evidence; (2) did not err in determining that the statements Defendant sought to suppress were voluntary; and (3) did not abuse its discretion by denying Defendant's motion to recuse. View "State v. Clark" on Justia Law