Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of one count of intentional, knowing, or depraved indifference murder, one count of depraved indifference murder, and one count of arson and sentence of two life terms for the murders, holding that there was no error in Defendant's sentence.The trial court set Defendant's basic sentence for both murders at life imprisonment based on the application of two of the aggravating circumstances named in State v. Shortsleeves, 580 A.2d 145 (Me. 1990) - premeditation-in-fact and extreme cruelty. On appeal, Defendant challenged both aggravating circumstances. The Supreme Judicial Court affirmed, holding (1) the court did not err by applying premeditation-in-fact and extreme cruelty as aggravating circumstances to justify imposition of a basic sentence of life imprisonment for both counts of murder; and (2) the trial court precisely complied with the legal principles that apply to setting the basic sentence. View "State v. De St. Croix" on Justia Law

The Supreme Judicial Court affirmed the divorce judgment entered by the district court, holding that district court did not err in its property distribution between the parties.On appeal, Dorothy Lovell argued (1) the district court erred when it determined that Paul Lovell was not judicially estopped from arguing that a retirement account was marital property, despite a contrary provision in a previous divorce judgment; (2) she received insufficient notice of the district court's intention to reevaluation the distribution of the entire marital estate; and (3) the district court committed obvious error when it determined that part of the retirement account was marital property. The Supreme Judicial Court affirmed, holding (1) the doctrine of judicial estoppel did not apply here; (2) Dorothy's due process argument was waived; and (3) the district court did not err in its property distribution. View "Lovell v. Lovell" on Justia Law

The Supreme Judicial Court affirmed the business and consumer docket's entry of final judgment reaffirming a partial summary judgment on the complaint filed by Michael Zelman and a counterclaim filed by Andrew and Zelman Family Business Holdings, LLC (ZFBH), holding that the business and consumer court had subject matter jurisdiction.Michael brought this action both individually and as personal representative of the Estate of Estelle Betty Zelman asking the superior court to dissolve and liquidate ZFBH. Andrew and ZFBH filed an answer and counterclaim. The court entered a final judgment concluding that Andrew was not a manager of ZFBH and that the sole remaining manager of ZFBH had died and declining to dissolve ZFBH. The Supreme Judicial Court affirmed, holding (1) the business and consumer court had subject matter jurisdiction and personal jurisdiction; and (2) the court correctly concluded that William did not have the authority to appoint Andrew as a manager of ZFBH. View "Zelman v. Zelman" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Workers' Compensation Board Appellate Division vacating the judgment of the administrative law judge (ALJ) denying Lorraine Somers's petition to have her benefits reinstated, holding that the Appellate Division did not err.The Board entered a decree permitting S.D. Warrant Company and its insurer (collectively, S.D. Warren) to discontinue paying Somers partial incapacity benefits when those payments had reached the 520-week statutory limit. Somers filed a petition to have her benefits reinstated, arguing that S.D. Warren failed to comply with Me. W.C.B. Rule, ch. 2, 5(1) (the former Rule) by not providing her with notice that she could be eligible for an extension of weekly benefits. An ALJ denied the petition. The Appellate Division vacated that decision. The Supreme Judicial Court affirmed, holding that S.D. Warren was required to give Somers notice pursuant to the former Rule before terminating her benefits. View "Somers v. S.D. Warren Co." on Justia Law

The Supreme Judicial Court affirmed the interlocutory order of the superior court denying Defendant's motion to dismiss on double jeopardy grounds a superseding indictment against him, holding that neither the United States Double Jeopardy Clause nor its counterpart in the Maine Constitution barred the State from retrying Defendant on the superseding indictment.On appeal, Defendant argued that the superior court erred in denying his motion to dismiss because the dismissal of the original indictment against him after the jury was empaneled and sworn barred the State from charging him twice with the same offense. The Supreme Judicial Court clarified the implications of a defective indictment for purposes of the Double Jeopardy Clauses of the state and federal Constitutions and affirmed, holding (1) jeopardy attached in Defendant's trial; but (2) the trial court's dismissal of the indictment was not the equivalent of an acquittal and did not bar retrial. View "State v. Shirey" on Justia Law

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