Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's sentence imposed after he pled guilty to the intentional and knowing murder of his wife, holding that the sentencing court followed proper sentencing procedures and appropriately exercised its discretion in determining the sources and types of information to consider.After a sentencing hearing, the court sentenced Defendant to forty years in prison. Defendant appealed, arguing that the court misapplied the first step of the sentencing analysis required by Me. Rev. Stat. 17-A, 1252-C by failing to conduct a proper comparison of the circumstances of his crime to similar murders. The Supreme Judicial Court affirmed, holding (1) the court properly exercised its discretion in considering comparable sentences when imposing Defendant's sentence; and (2) the court thoughtfully considered the relevant facts and sentencing principles in determining Defendant's sentence. View "State v. Leng" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court in favor of John Bump on Wells Fargo Bank's foreclosure complaint, holding that the court did not err by concluding that a 2015 order dismissing without prejudice Wells Fargo's earlier action seeking foreclosure on the same mortgage did not vacate the final judgment in Bump's favor that had been entered in 2013 in that same case.Wells Fargo filed a foreclosure action in the district court in 2009. After a bench trial in 2013, the court entered judgment on the merits in favor of Bump. In 2015, the court granted Wells Fargo's motion to dismiss the 2009 action without prejudice. In 2016, Wells Fargo filed a new action to foreclose on the same mortgage. In 2020, the court entered judgment in favor of Bump, stating that it took notice of the 2013 final judgment and concluding that the 2015 order of dismissal without prejudice did not operate to vacate that judgment. The court then determined that Wells Fargo's entire claim was barred by res judicial given the 2013 judgment. The Supreme Judicial Court affirmed, holding that the district court (1) properly concluded that the preclusive effect of the 2013 judgment barred the present action; and (2) did not abuse its discretion in taking judicial notice of the prior judgment. View "Wells Fargo Bank v. Bump" on Justia Law

The Supreme Judicial Court dismissed this appeal from an order of the superior court denying Down East Orthopedic Associates, P.A.'s motion to dismiss Carol Cutting's complaint for medical malpractice, holding that Down East had not established that this was the rare case that warranted the application of the judicial economy exception to the final judgment rule.Cutting filed a federal malpractice action against Down East asserting counts for failure to obtain informed consent and medical malpractice. The federal court dismissed the federal malpractice case for lack of subject matter jurisdiction. Cutting then filed a complaint in the state superior court asserting the same causes of action as those in her federal malpractice case. Down East filed a motion to dismiss on claim preclusion grounds. The superior court denied the motion, and Down East appealed. The Supreme Court dismissed the appeal, holding that this appeal does not come within the judicial economy exception to the final judgment rule. View "Cutting v. Down East Orthopedic Associates, P.A." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court sentencing Defendant to fifteen years of imprisonment after he was convicted by a jury of two counts of aggravated trafficking in scheduled drugs and one count of criminal forfeiture, holding that the sentencing court did not improperly engage in "double counting."On appeal, Defendant argued that the trial court erred when it considered the commercial motive of his offenses both when it set the basic sentence and when it set the maximum sentence. The Supreme Judicial Court affirmed, holding that the trial court properly considered different aspects of the commercial nature of the offense at each step of the court's analysis. View "State v. Plummer" on Justia Law

The Supreme Judicial Court affirmed the opinion of the Workers' Compensation Board Appellate Division agreeing with the conclusion of the administrative law judge (ALJ) that Darla Potter, an aquaculture worker, was not a "seaman" within the meaning of the Jones Act, 46 U.S.C.S. 30104, holding that the Appellate Division did not err.The Appellate Division affirmed the decree of the ALJ granting Potter's petitions for award of compensation for injuries sustained in the course of her employment with Cooke Aquaculture USA, Inc. At issue on appeal was whether Potter's claims fell within the jurisdiction of federal admiralty law or state workers' compensation law. The Supreme Judicial Court affirmed, holding that Potter was not a seaman within the purview of the Jones Act. View "Potter v. Great Falls Insurance Co." on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing with prejudice a complaint for protection from abuse that Plaintiff brought on behalf of her three minor children against the children's father (Father), holding that due process did not require that the court dismiss this matter with prejudice.After Plaintiff filed her complaint for protection from abuse on behalf of her children, Father was arrested. Father's bail conditions prohibited contact between Father and the children. Plaintiff moved to dismiss the complaint without prejudice given that Father's bail conditions protected the children. The court denied Plaintiff's motion and dismissed the case with prejudice, concluding that it did not have the discretion to grant Plaintiff's motion. The Supreme Judicial Court vacated the judgment, holding that the court erred as a matter of law when it determined that due process and Me. Rev. Stat. 4006(1) required it to either hold the hearing as scheduled or dismiss the complaint with prejudice and that, pursuant to Me. R. Civ. P. 41(a)(2), the court had the authority and discretion to dismiss Plaintiff's complaint without prejudice. View "Doe v. Hills-Pettitt" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of domestic violence assault, holding that Defendant was not prejudiced.On appeal, Defendant argued (1) the trial court erred by allowing testimony from Defendant's fifteen-year-old daughter concerning Defendant's parenting practices, and (2) the State committed prosecutorial misconduct by commenting on admissible evidence during its cross-examination of her. The Supreme Judicial Court affirmed, holding (1) because, in her opening statement, Defendant indicated her pursuit of the parental discipline justification found at Me. Rev. Stat. 17-A, 106(1), the court did not err in admitting evidence of Defendant's parenting; and (2) the State committed prosecutorial conduct by eliciting and commenting on evidence that other children had been removed from Defendant's home, but the error was not so prejudicial that it affected the outcome of the proceeding. View "State v. Pratt" on Justia Law

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