Justia Maine Supreme Court Opinion Summaries

The case involves Billie S., who appealed from a judgment by the District Court (Bangor, Roberts, J.) which terminated her parental rights to her children pursuant to 22 M.R.S. § 4055(1)(B)(2) (2023). The mother argued that the judgment did not provide sufficient independent findings of fact to support the termination of her parental rights. The Maine Supreme Judicial Court agreed with the mother's contention.The trial court based its decision on evidence from various sources including the Department of Health and Human Services caseworker's testimony, guardian ad litem reports, and the petitions for termination. However, the judgment simply incorporated the entirety of these sources as its "specific findings" instead of providing an independent articulation of the specific facts that formed the basis of the court’s ultimate findings regarding the mother’s parental unfitness and the best interests of the children.The Maine Supreme Judicial Court held that these were not the “specific findings of fact” required by Rule 52(a) or prior decisions. The court could not infer factual findings in a termination case when the adequacy of the findings was the issue at hand. As a result, the court vacated the judgment due to its lack of adequate findings that would sufficiently inform the mother and the court of the reasoning behind the decision. The case was remanded to the District Court for further proceedings consistent with this opinion. View "In re Children of Billie S." on Justia Law

In the case before the Maine Supreme Judicial Court, the Office of the Public Advocate (the appellant) contested a decision by the Public Utilities Commission (PUC) that approved an amended special rate contract between Bangor Natural Gas Company and Bucksport Generation LLC. The appellant argued that the PUC applied the wrong standard in reviewing the contract, which led to unjust or unreasonable rates and undue or unreasonable preference for Bucksport Generation over other Bangor Gas customers. The appellant also argued that the PUC's order should be vacated because it relied on evidence not included in the record.The court disagreed with the appellant's first argument and found the second argument waived, thereby affirming the PUC's order. The court held that the PUC was within its discretion to apply different standards of review for special rate contracts depending on the type of utility service at issue. Given the competitive nature of the natural gas market in Maine, the court deemed the PUC's standard reasonable.Regarding the rates, the court found that the PUC’s approval of the special rate contract did not result in unjust, unreasonable, or discriminatory rates for other Bangor Gas customers. The court noted that incentivizing continued financial contributions from Bucksport Generation to Bangor Gas’s fixed costs was justifiable.Finally, the court ruled that the appellant's argument about the PUC's failure to create an evidentiary record was waived due to the appellant's failure to raise the issue at the PUC level. However, the court acknowledged the appellant's point and advised the PUC to clarify its regulations regarding what materials constitute the evidentiary record in proceedings where an evidentiary hearing is not held. View "Office of the Public Advocate v. Public Utilities Commission" on Justia Law

In this case, the Maine Supreme Judicial Court affirmed a lower court's decision to terminate a mother's parental rights to her two children. The mother appealed the termination of her rights, asserting that she was deprived of effective legal counsel during the proceedings. The lower court had determined that the children were in jeopardy due to the mother's chronic alcohol abuse, unsafe behavior, and poor decision-making, which included permitting a convicted sex offender to care for the children unsupervised. Despite repeated opportunities, the mother failed to demonstrate sufficient improvement to safely care for her children.The mother also proposed that her own mother or aunt should be appointed as permanency guardians for the children. However, the court found that neither individual was suitable for this role due to their loyalties to the mother and lack of objectivity regarding her addiction and reckless behavior. As such, the court determined that adoption was in the children's best interests.On appeal, the Maine Supreme Judicial Court found no evidence of ineffective assistance of counsel. The court noted that the attorney had adequately presented the mother's case and had advocated for the possibility of a familial permanency guardianship. The court concluded that the mother's claim of ineffective assistance did not meet the threshold for a prima facie case, as there was no evidence of serious incompetency, inefficiency, or inattention from her attorney, nor was there any indication that the outcome of the trial was unjust. Consequently, the decision to terminate the mother's parental rights was upheld. View "In re Children of Shannevia Y." on Justia Law

In this case, the Maine Supreme Judicial Court was called to determine issues regarding the distribution of assets under a will and trust, and personal jurisdiction. The case arose from a dispute between two brothers, John R. Luongo and Michael A. Luongo Jr., regarding their mother's estate and a trust she established. The Superior Court had previously divided the property of the estate between the brothers and dismissed two counts of John's complaint, arguing that it could not exercise personal jurisdiction over Michael.Upon review, the Maine Supreme Judicial Court determined that the Superior Court did not have subject matter jurisdiction to distribute the assets under the will and the related trust. The authority to resolve disputes over the distribution of assets under a will rests solely with the Probate Court. Therefore, the court vacated the lower court's order distributing the assets of the estate.Regarding personal jurisdiction, the court found that the Superior Court correctly concluded that it did not have personal jurisdiction over Michael for claims related to the trust. This was due to the fact that the trust was established as a Massachusetts trust with its principal place of administration in Massachusetts and the process to transfer the trust’s administration to Maine was not completed by either trustee.The court affirmed the dismissal of Counts 1 and 3 of John’s complaint, related to the trust, but vacated the judgment in all other respects, including Michael’s counterclaim for conversion. The case was remanded for dismissal of the remaining counts of John’s complaint and Michael’s counterclaim for conversion. View "Luongo v. Luongo" on Justia Law

In the case before the Maine Supreme Judicial Court, Taylor A. Pelletier was convicted of multiple crimes, including two counts of kidnapping with a dangerous weapon, two counts of aggravated assault, one count of domestic violence threatening with a dangerous weapon, and one count of domestic violence terrorizing with a dangerous weapon. The trial court found Pelletier guilty based on evidence from a home security system and the victim's testimony, which the court found credible.Pelletier appealed his conviction, raising three main issues: the sufficiency of the evidence supporting his kidnapping conviction, the sufficiency of the indictment for the first count of kidnapping, and the trial court's denial of his motion to dismiss for alleged discovery and Brady violations.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court found that the evidence was sufficient to support the kidnapping conviction. The court held that Pelletier had confined the victim inside the house for a substantial period, which went beyond the time necessary to commit the assaults. The court also found that the indictment adequately stated the charges against Pelletier, giving him sufficient notice to prepare his defense. Lastly, the court held that the trial court did not abuse its discretion in denying Pelletier's motion to dismiss for discovery and Brady violations. The court held that the trial court's sanction of a continuance was sufficient to mitigate any prejudice caused by the State's late disclosure of evidence. View "Maine v. Pelletier" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court for attempted murder and other crimes with respect to Defendant's contended errors but vacated Defendant's sentences with respect to domestic violence assault and domestic violence terrorizing, holding that those sentences exceeded the maximum allowable under Me. Rev. Stat. 17-A, 1604(1)(D).On appeal, Defendant argued that the trial court abused its discretion by imposing a discovery sanction under M.R.U. Crim. P. 16(e) and that the jury venire was not drawn from a fair cross-section of the community. The Supreme Judicial Court affirmed the convictions but vacated the sentences in part, holding (1) the trial court's discovery sanction constituted a fundamentally fair balance between the parties' competing interests; (2) Defendant did not sufficiently preserve or present a sufficient record for the Supreme Court to reach Defendant's second contention; and (3) the trial court erred by entering a one-year sentence for Defendant's convictions for domestic violence assault and domestic violence, both class D misdemeanors. View "State v. Page" on Justia Law

The Court of Appeals affirmed the judgment of default and forfeiture of $17,815 in cash bail entered after the trial court denied Defendant's motion to set aside the forfeiture of that portion of his deposited cash bail, holding that the trial court did not abuse its discretion in denying Defendant's motion to set aside the forfeiture.On appeal, Defendant argued that the trial court abused its discretion in denying his motion because the bail bond did not explicitly warn him of forfeiture as a potential consequence for violating the condition of his release that he commit no violation of a bail condition. The Court of Appeals affirmed, holding that, on the record, the trial court did not abuse its discretion in denying Defendant's motion as to $17,815 of his deposited cash bail. View "State v. Covington" on Justia Law

The Supreme Judicial Court affirmed in all respects a judgment of conviction of two counts of murder and other weapons-related counts entered by the trial court following a jury trial on the murder charges and a bench trial on the other charges, holding that there was no error or abuse of discretion.Specifically, the Supreme Judicial Court held that the trial court (1) did not err by denying Defendant's request to present evidence to the jury that a State investigator had monitored telephone calls between Defendant and his attorney while Defendant was in pretrial detention; (2) did not err by giving a jury instruction on accomplice liability; (3) did not err by not granting a mistrial based on certain comments made by the prosecutor during the State's closing arguments; and (4) did not err in sentencing Defendant to life sentences on the murder charges. View "State v. Nightingale" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction of hindering apprehension or prosecution entered by the trial court following a jury trial, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not commit obvious error in allowing a closing argument implying that Appellant had a burden of proving that the State's witnesses had a motive to lie and instructing the jury that it could "consider whether there has been any evidence introduced of any motive or lack of motive for a witness to exaggerate or lie"; and (2) the trial court did not abuse its discretion in denying Appellant's motion for voir dire of jurors filed after learning that one witness said “good luck” to the jurors while leaving the courtroom. View "State v. Lipscombe" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court determining that the Aroostook County Commissioners had jurisdiction over an appeal of a municipality's denial of a tax abatement application by Cassidy Holdings, LLC, holding that there was no error.Cassidy, which owned nonresidential property with an equalized municipal valuation of $1 million or greater, requested a partial abatement of its 2021 property taxes. The City of Caribou's Board of Assessors denied the request. The Commissioners declined to hear Cassidy's ensuing appeal on the grounds that they lacked subject matter jurisdiction. The superior court remanded the case for the Commissioners to proceed on the merits, concluding that the Commissioners erred in determining that they lacked jurisdiction over the abatement appeal. The Supreme Judicial Court affirmed, holding that the plain language of 36 Me. Rev. Stat. 844 provides for concurrent jurisdiction before either the Commissioners or the State Board. View "Cassidy Holdings, LLC v. Aroostook County Commissioners" on Justia Law