Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court vacated the judgment of conviction for assault and violation of condition of release entered by the trial court after a jury trial, holding that the court erred in instructing the jury concerning the justification of defense of property set forth in Me. Rev. Stat. 17-A, 105.After a second trial, a jury found Defendant guilty of violating a condition of release. Defendant appealed, arguing that the trial court erred in instructing the jury concerning the justification of defense of property. The Supreme Court agreed and remanded the matter for a new trial, holding (1) the trial court's oral and written instructions concerning the statutory justification of defense of property was erroneous in more than one respect; and (2) the errors were highly prejudicial and constituted obvious error. View "State v. Lee" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court granting Pat Doe a protection from abuse order against Appellant on behalf of Doe's two minor children, holding that the district court erred as a matter of fact and law by finding that Appellant committed abuse within the meaning of Me. Rev. Stat. 19-A, 4002.Doe filed a complaint for protection from abuse on behalf of his two minor children against Appellant, the children's maternal grandmother. The court issued a protection order prohibiting Appellant from having any contact with the children after determining that Appellant's actions in taking the children to Arizona and keeping them there after their mother's death constituted abuse within the meaning of the protection from abuse statute. The Supreme Judicial Court disagreed, holding that, on this record, there was insufficient evidence to support the court's finding that Appellant knowingly restricted the children's movement without consent or lawful authority to do so. View "Doe v. Batie" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Plaintiffs' motion for a preliminary injunction seeking to enjoin the Secretary of State from rejecting certain ballots, holding that Plaintiffs failed to show a clear likelihood of success on their complaint for declaratory relief.Plaintiffs filed a complaint against Maine's Secretary of State and Attorney General seeking a declaration that the statutory deadline established by Me. Rev. Stat. 21-A, 626(2) for receiving absentee ballots in an election and statutory provisions governing the validation and rejection of absentee ballots - Me. Rev. Stat. 21-A, 756(2), 759(3), (5), 762 - violate the federal and state Constitutions. Plaintiffs sought to enjoin the Secretary from rejecting ballots postmarked on or before Election Day and that arrive at the election office within a minimum of ten days after Election Day and rejecting absentee ballots of otherwise eligible Maine voters without giving the voter an opportunity to cure their ballot or verify their identity. Plaintiffs moved for a preliminary injunction granting the relief requested in the complaint. The superior court denied relief. The Supreme Judicial Court affirmed, holding that absentee voters will be afforded fundamental fairness in the November 2020 election, and therefore, the superior court did not abuse its discretion in denying injunctive relief. View "Alliance for Retired Americans v. Secretary of State" on Justia Law

In this appeal from a residential foreclosure judgment, the Supreme Judicial Court clarified the criteria under the business record exception to the hearsay rule for admitting into evidence records that a business has obtained from another entity and integrated into its own records or operations by reaffirming the interpretation set forth in Northeast Bank & Trust Co. v. Soley, 481 A.2d 1123, 1127 (Me. 1984).Specifically, the Supreme Court held that a record that one business has received from another is admissible under Me. R. Evid. 803(6) without testimony about the practices of the business that created the record, provided that (1) the proponent of admission establishes that the receiving business has integrated the record into its own records, has established the accuracy of the contents of the record, and has relief on the record in the conduct of its operations; and (2) the opponent of admission has not shown that the record is nonetheless not sufficiently trustworthy to be admitted. View "Bank of New York Mellon v. Shone" on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the district court terminating Mother's parental rights to three of her children, holding that the court did not clearly err in finding at least one ground of parental unfitness by clear and convincing and did not abuse its discretion in concluding that termination was in the children's best interests.The district court terminated Mother's parental rights to three of her children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a), (B)(2)(a), (b)(i)-(iv). The Supreme Judicial Court affirmed, holding that the express findings the court made were sufficient to support its determination to terminate Mother's parental rights. View "In re Children of Loretta M." on Justia Law