Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court entering a protection form abuse order against Mark Forino and in favor of Forino and Pat Doe's two children after a hearing on Doe's complaint for protection from abuse, holding that the district court did not err.On appeal, Forino argued that the district court erred when it denied his motion to dismiss Doe's complaint on res judicata grounds and his motion in limine to exclude evidence relating to allegations in Doe's previous complaint against him for protection from abuse. The Supreme Judicial Court affirmed after emphasizing the need for caution in applying res judicata in cases regarding family matters, holding that res judicata did not bar Doe's second complaint. View "Doe v. Forino" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered by the superior court ejecting Defendant from real property pursuant to Me. Rev. Stat. 14, 6701-7053, holding that the trial court properly entered judgment for Plaintiffs, the property owners.Plaintiffs filed a complaint seeking to eject Defendant from the property and obtain a writ of possession. The trial court granted Plaintiffs' motion for summary judgment for their claim of ejectment. The Supreme Judicial Court affirmed, holding that the trial court (1) correctly interpreted Me. Rev. Stat. 14, 6961 and the legal framework governing real actions for ejectment; (2) did not err in entering partial summary judgment for Plaintiffs granting them a writ of possession; and (3) did not err in concluding that its judgment rendered Defendant's counterclaim for declaratory judgment moot. View "Ogden v. Labonville" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing the three-count complaint filed by John Doe, DO, against the Maine Board of Osteopathic Licensure, holding that Doe failed to state a claim upon which relief may be granted as to any of his claims.Two of Doe's complaints sought a declaration that pending disciplinary complaints against him must be dismissed because the Board did not provide him the required notice, and the third count claimed that the Board failed to address the complaints in a timely manner. The superior court dismissed the first two counts for failure to state a claim and the third count for lack of subject matter jurisdiction. The Supreme Judicial Court affirmed, holding that dismissal of all three counts was proper on the grounds that Doe failed to state a claim upon which relief may be granted. View "Doe v. Maine Board of Osteopathic Licensure" on Justia Law

The Supreme Court affirmed the judgment of the district court awarding almost $400,000 in this action to enforce a divorce judgment, holding that the trial court's factual findings were supported by competent evidence.In 2018, Frances Quirk filed a motion to enforce her divorce judgment from 1973. Quirk alleged that John Quirk, her ex-husband, was obligated to pay her forty-five dollars weekly in spousal support and owed her $97,875 in arrears. John asserted laches as an affirmative defense. The court awarded Frances spousal support, interest, and attorney fees, finding that John had not made payments since 1977, that Frances had not pursued the payments because of John's threatening behavior, and that John had not been prejudiced by Frances's delay in enforcing the obligation. The Supreme Court affirmed, holding (1) John's laches defense failed; (2) the court did not abuse its discretion by awarding the full amount of post-judgment interest to Frances; (3) the statutory presumption of satisfaction was overcome in this case; and (4) the court did not abuse its discretion by awarding Frances all of her attorney fees. View "Quirk v. Quirk" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court affirming the decision of the Commissioner of the Department of Health and Human Services (Department) accepting the recommendation of an administrative presiding officer that the Department correctly established and maintained a recoupment claim for $116,852 against Appellant, an oral surgeon, holding that remand was required as to one aspect of the Department's decision.Appellant was a MaineCare provider whose practice was based in Auburn. After Appellant retired, the Department issued a notice of violation, alleging that Appellant had been overpaid. After an administrative hearing, the Department reduced its claim to $116,852. The presiding officer upheld the Department's recoupment claim. The Commissioner adopted the presiding officer's recommended decision in full. The Supreme Judicial Court reversed in part and remanded the case, holding (1) because the Department failed to explain its decision imposing the maximum allowable penalties for Appellant's failure properly to document time spent with patients following his administration of anesthesia, the Court was unable to determine whether the Department properly exercised its discretion; and (2) Appellant was not entitled to relief on his remaining allegations of error. View "Palian v. Department of Health and Human Services" on Justia Law

In this action brought by Plaintiff, an inmate, the Supreme Judicial Court vacated the portions of the superior court's judgment denying injunctive relief, restoring good-time credit for the period of Plaintiff's nondisciplinary segregation, and entering judgment for Defendants on Plaintiff's 42 U.S.C.S. 1983 claim, holding that restoration of Plaintiff's "good time" was not an available remedy through judicial review of the Department's disciplinary action against Plaintiff and that the Maine Constitution's mandate regarding separation of powers does not preclude an award of injunctive relief on a section 1983 claim against the Department of Corrections.Plaintiff filed a complaint seeking judicial review of a disciplinary decision of the Department and injunction for violations of his civil rights. The superior court vacated the disciplinary decision but concluded that it was prohibited from entering injunctive relief on the section 1983 claim. The court then restored good-time credit for the period of nondisciplinary segregation as a remedy for Plaintiff's Rule 80C claim and entered judgment for Defendants on the section 1983 claim. The Supreme Judicial Court vacated the judgment in part and remanded for the court to determine whether injunctive relief should be awarded, enter judgment in Plaintiff's favor on his section 1983 claim and ordered the restoration of good-time credit for the period of Plaintiff's nondisciplinary segregation as a remedy for the constitutional violations alleged in his section 1983 claim. View "Burr v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder of a deputy sheriff, holding that there was no error, clear or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in permitting the State to introduce in-court demonstrations of the possible circumstances of the shooting and in allowing the demonstration to be presented to the jury over Defendant's Rule 403 objection; (2) the trial court did not err in partially denying Defendant's motion to suppress statements he made to detectives after his arrest; and (3) there was no error in the court's sentencing proceedings, and the court did not abuse its discretion in imposing a sentence of life imprisonment. View "State v. Williams" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder, entered by the trial court following Defendant's guilty plea, holding that the trial court did not abuse its discretion in denying Defendant's motion to withdraw her guilty plea and did not abuse its discretion or misapply sentencing principles in sentencing Defendant.Specifically, the Supreme Judicial Court held (1) contrary to Defendant's asserting on appeal, the court did not abuse its discretion in concluding that Defendant understood the nature of the offense charged and voluntarily entered the plea, and therefore, the trial court did not err in denying Defendant's motion to withdraw her guilty plea; and (2) the trial court did not misapply sentencing principles in determining the basic period of incarceration. View "State v. Weyland" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of aggravated assault, domestic violence criminal threatening, and other offenses, holding that there was no error, obvious or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in admitting expert testimony regarding strangulation; (2) the trial court did not abuse its discretion in imposing consecutive sentences; and (3) the trial court did not err by considering Defendant's criminal history as an aggravating factor at sentencing. View "State v. Treadway" on Justia Law

The Supreme Court answered two of three questions of state law certified by the United States Court of Appeals for the First Circuit and declined to answer the second question in this case brought about by the City of South Portland's amendment to its zoning ordinance by prohibiting the bulk loading of crude oil onto any marine vessel.Portland Pipe Line Corporation (PPLC) planned to pipe crude oil from its facility in Canada to the City of South Portland, where the oil would then be loaded onto tankers in the City's harbor. After the City enacted its ordinance at issue, called the "Clear Skies Ordinance," PPLC and American Waterways Operators (collectively, PPLC) filed a complaint seeking a declaration that, inter alia, the Ordinance was preempted by Me. Rev. Stat. 38, 556. The federal district court entered summary judgment against PPLC. On appeal, the First Circuit certified questions of state law to the Supreme Court. The Supreme Court held (1) PPLC's license was not an "order," as that term is used in Me. Rev. Stat. 38, 556; and (2) independent of section 556, there was no basis for finding that Maine's Coastal Conveyance Act impliedly preempts the City's Clear Skies Ordinance. View "Portland Pipe Line Corp. v. City of South Portland" on Justia Law