Justia Maine Supreme Court Opinion Summaries

The Supreme Court affirmed in part and vacated in part the judgment of the superior court granting a partial summary judgment in favor of Defendants on count two of Plaintiff's second amended complaint seeking a declaratory judgment interpreting and/or reforming part of the Shea Family Living Trust, holding that the judgment was proper except as to reformation.At issue was a trust established by Patricia and William Shea that included stock issued by a particular bank. When William died, the bank redeemed its stock, and after Patricia died, the successor trustee distributed the remaining assets of the trust, which no longer included the bank stock. Plaintiffs, Patricia's nieces and nephews, brought this action, arguing that Plaintiffs were entitled to the proceeds from the sale of the bank stock. In count two, Plaintiffs sought a declaratory judgment that the trust provided for a general devise of the bank stock and, alternatively, brought a claim for reformation. The court entered partial summary judgment for Defendant on count two of the complaint and denied and dismissed the reformation claim. The Supreme Court vacated the judgment as to the reformation claim and otherwise affirmed, holding that Defendant was entitled to summary judgment on the reformation claim. View "Connary v. Shea" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Secretary of State to draft a single ballot question for a direct initiative, holding that the Secretary of State did not err or abuse her discretion in writing a single question in this instance.The direct initiative at issue proposed "An Act To Require Legislative Approval of Certain Transmission Lines, Require Legislative Approval of Certain Transmission Lines and Facilities and Other Projects on Public Reserved Lands and Prohibit the Construction of Certain Transmission Lines in the Upper Kennebec Region.” Appellant argued that the Secretary of State was statutorily required to prepare a separate question for each of three separate issues addressed by the direct initiative. The Supreme Judicial Court disagreed, holding that the Secretary of State did not abuse her discretion in reading the initiated bill in the conjunctive and drafting a single, concise ballot question describing the single Act. View "Caiazzo v. Secretary of State" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court accepting Defendant's conditional guilty plea to escape, holding that, by separately trying Defendant for criminal threatening in Sagadahoc County and then for escape in Kennebec County, the State violated Me. Rev. Stat. 17-A, 14.Defendant was arrested for criminal threatening with a dangerous weapon shortly after he allegedly left the custody of a psychiatric center without permission. A jury acquitted Defendant of the criminal threatening charge in Sagadahoc County. Thereafter, the State charged Defendant with escape in Kennebec County. Defendant entered a conditional guilty plea to the charge and then appealed. The Supreme Judicial Court vacated the trial court's judgment, holding (1) Sagadahoc County was a proper venue to prosecute Defendant for escape because it was the county in which he was apprehended; and (2) the trial court's finding that Defendant's alleged threat against a family member arose from the same criminal episode was supported by the record. View "State v. Gessner" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court declining Patricia Monteith's request to register in Maine a child support order issued in Maryland against George Monteith as to the parties' four children, holding that the district court did not err.In 2002, Patricia and George were divorced in Maine by a decision requiring George to pay child support to Patricia. Patricia and the children subsequently moved to Maryland. Ten years after the divorce, Patricia initiated a proceeding in Maryland seeking modification of the Maine child support order. The Maryland modification proceedings culminated in the entry of an agreed-to modified child support order. The district court vacated the registration of the Maryland order, concluding that the order was void ab initio based on the parties' failure to file the required consents in Maine to the Maryland court's exercise of jurisdiction. The Supreme Judicial Court affirmed, holding that the parties' failure to file consents pursuant to Me. Rev. Stat. 19-A, 2965(2)(A) deprived the Maryland court of subject matter jurisdiction to modify Maine's 2002 support order, rendering the Maryland order void ab initio. View "Monteith v. Monteith" on Justia Law

The Supreme Judicial Court affirmed Defendant's sentence of forty years' imprisonment imposed in connection with his guilty plea to murder, holding that the trial court did not misapply any principle or abuse its discretion in its sentencing analysis or in its exercise of its sentencing power.Defendant pleaded guilty of intentional or knowing murder. Based on its findings and consideration of sentences imposed in comparable cases, the trial court set the basic sentence at fifty to fifty-five years' imprisonment. After weighing the aggravating and mitigating factors, the court set the final sentence of forty years' imprisonment. The Supreme Judicial Court affirmed the sentence, holding that although the court was not required to consider comparable cases, the court correctly applied sentencing principles at both steps of the sentencing analysis. View "State v. Bentley" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court vacating the determination of the Town of Wells Zoning Board of Appeals (ZBA) denying Plaintiff's application for two setback variances on the grounds that Plaintiff had not met his burden of proof, holding that the evidence did not compel the ZBA to grant him a variance.The ZBA denied Plaintiff's application on the basis that he did not meet his burden of proof to show that granting the variances would not alter the essential character of the locality. The superior court vacated the ZBA's determination, concluding that Plaintiff had met his burden of proof. The Supreme Judicial Court vacated the judgment below and remanded with instructions to affirm the ZBA's denial, holding that the ZBA properly decided that Plaintiff failed to show that the nature of his proposed residence with the variances would conform with the neighborhood as zoned and would not degrade the value of surrounding environmental structures. View "Hill v. Town of Wells" on Justia Law

The Supreme Court vacated the judgment of the district court denying Mother's second motion for relief from the judgment of the district court terminating her parental rights to her four children, holding that Mother made a prima facie showing that she received ineffective assistance of counsel at the trial phase and post-judgment phase of the case.Mother did not appear for the termination hearing, and trial counsel was also absent when the hearing began. After Mother's parental rights were terminated trial counsel moved to withdraw from the case, and interim counsel was appointed to represent Mother. Appellate counsel filed a Rule 60(b) motion for relief of judgment, alleging ineffective assistance of trial counsel and interim counsel. The trial court denied the motion as untimely. The Supreme Court vacated the judgment, holding (1) Mother made a prima facie showing of ineffective assistance of counsel at both the trial phase of the case and the post-judgment phase; and (2) Mother's Rule 60(b) motion was both proper and timely in light of the extraordinary circumstances presented in this case. View "In re Children of Kacee S." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for knowing or intentional murder and the denial of his motion for a new trial, holding that there was no error.On appeal, Defendant argued that the trial court erred or abused its discretion in excluding alternative-suspect evidence, failing to provide an adequate explanation in setting the basic sentence, and denying his motion for a new trial based on a juror's statements made after Defendant's conviction. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion in excluding alternative-suspect evidence as insufficient to establish a reasonable connection to the crime; (2) the court did not misapply sentencing principles in setting a basic sentence of forty to forty-five years' incarceration; and (3) the court did not err or abuse its discretion in denying Defendant's motion for a new trial. View "State v. Daly" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment against the Portland Regional Chamber of Commerce on its claims that voter-initiated legislation establishing an emergency minimum wage in Portland violated the Portland City Code and the Maine Constitution, holding that there was no error.After voters approved the initiative at issue, Plaintiffs, employers with employees in Portland, filed a complaint asserting that the initiative was invalid and that, if it was valid, it would not take effect until January 1, 2022. Intervenors filed a cross-claim seeking declaratory relief establishing the effective date of the emergency provision as December 6, 2020. The superior court concluded that the emergency provision was validly enacted pursuant to the Maine Constitution and the Portland City Code and dismissed Intervenors' cross-claims. The Supreme Judicial Court affirmed, holding (1) the initiative was validly enacted; and (2) the emergency provision was effective as of January 1, 2022. View "Portland Regional Chamber of Commerce v. City of Portland" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming a decision of the State Board of Property Tax Review upholding the Town of Madison's denial of Madison Paper Industries' (MPI) request for a property tax abatement for the 2016-17 tax year, holding that the Board made no errors of law, and its findings were supported by competent evidence in the record.The Board found MPI's appraisal and its underlying factual assertions were not credible and that MPI had failed to meet its burden of persuasion. On appeal, MPI argued that the Board failed to apply the Maine Constitution's required that it apply the "just value" standard to valuing the property. The Supreme Judicial Court affirmed, holding that the Board's determinations were not erroneous and that its findings were supported by the evidence. View "Madison Paper Industries v. Town of Madison" on Justia Law