Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed separate judgments entered by the district court terminating Mother's and Father's parental rights to the children, holding that the district court did not err or abuse its discretion.Mother's parental rights were terminated pursuant to Me. Rev. Stat. tit. 22, 4055(1)(A)(1)(a) and (B)(1), and Father's parental rights were terminated pursuant to Me. Rev. Stat. tit. 22, 4055(1)(B)(2)(a) and (b)(i)-(ii). The Supreme Judicial Court affirmed, holding (1) the district court did not err in finding that Mother knowingly and voluntarily contented to the termination of her parental rights; and (2) as to Father, the district court did not clearly err or abuse its discretion in finding at least one ground of parental unfitness and that termination was in the best interests of the children. View "In re Children of Brandon D." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for manslaughter, holding that the evidence admitted at trial was sufficient to prove beyond a reasonable doubt that Defendant caused the child victim's death.Defendant was convicted of manslaughter for the death of a seven-month-old infant. The sentencing court sentenced Defendant to eleven years' imprisonment, with all but five years and six months suspended, and four years' probation. On appeal, Defendant challenged the sufficiency of the evidence. The Supreme Judicial Court affirmed, holding that the court was justified in finding beyond a reasonable doubt that Defendant, acting with criminal negligence, caused the child's death. View "State v. Mackin" on Justia Law

The Supreme Judicial Court vacated the order entered by the superior court denying Defendant's motion to compel arbitration of, and dismissing all counts in, a complaint filed against it by Plaintiff, holding that the superior court did not make the statutorily required determination as to whether the parties agreed to arbitrate the dispute.In 2017, the parties entered into a contract whereby Defendant would provide payroll services to Plaintiff. In 2019, Plaintiff filed a complaint against Defendant asserting claims for fraud, negligence, and breach of contract. Defendant moved to dismiss the complaint and to compel arbitration under an arbitration clause contained in the parties' contract. The court denied Defendant's motion, holding that it could not be concluded as a matter of law that the parties entered into a valid agreement to arbitrate. The Supreme Judicial Court vacated the judgment, holding that remand was required because the trial court denied Defendant's motion without making the finding regarding arbitrability required by Me. Rev. Stat. 14, 5928(1). View "TPR, Inc. v. Paychex, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court against Appellant, guarantor of a promissory note held by Finance Authority of Maine (FAME), holding that the superior court correctly determined that neither of two of the default provisions contained in Article 9 of Maine’s Uniform Commercial Code - 11 M.R.S. 9-1607 and 9-1626 - required FAME to prove the reasonableness of its decision not to pursue the collateral before it could obtain a judgment against Appellant.FAME extended a loan to Harbor Technologies, LLC. Harbor executed a promissory note and security agreement under which its assets were pledged as collateral to secure the note. Appellant executed a personal guaranty of Harbor's obligations to FAME. After Harbor defaulted on the loan, FAME sued Appellant on his guaranty for the entire amount due. The circuit court entered judgment in favor of FAME. The Supreme Judicial Court affirmed, holding that, in light of the independent and unconditional nature of Appellant's guaranty, the court was correct when it determined that neither section 9-1607 nor section 9-1626 imposed a burden on FAME to prove the commercial reasonableness of its decision not to pursue the collateral before it could obtain a judgment against Appellant. View "Finance Authority of Maine v. Grimnes" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court entering a declaratory judgment in favor of Ingrid Doyon, Trustee of the Oscar Olson Jr. Trust, holding that the trial court erred in interpreting a 1941 deed that contained language restriction development of three lots in a subdivision.In 2012, Ingrid Doyon acquired the three lots - Lots 3, 5, and 72 - as trustee of her father's trust. Doyon subsequently conveyed two of the lots but retained her interest in Lot 72. In 2014, Doyon initiated a declaratory judgment action seeking a determination that the restrictive covenant burdening Lot 72 permitted her to construct a single family home and garage on the property. The court issued a judgment in favor of Doyon. The Supreme Judicial Court vacated the judgment, holding that the 1941 deed unambiguously limited the construction that could take place on Lot 72 to a garage to be used with Lot 3, subject to certain setback specifications. View "Doyon v. Fantini" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court granting Susan Colucci's complaint for divorce, holding that the court did not have an adequate evidentiary basis from which it could make the findings necessary for it to set aside the parties' dog to the correct party.On appeal, Stephen Colucci argued that the district court erred in awarding the parties' dog, Louise, to Susan because the dog was his nonmarital property. The Supreme Judicial Court vacated the judgment, holding that because the parties did not present any evidence of who, whether Susan or Stephen, acquired Louise five years before the marriage, the district court should have reopened the record for the parties to submit additional evidence regarding the ownership of Louise prior to entering a final judgment. The Court remanded the case for further proceedings. View "Colucci v. Colucci" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of five counts of unlawful sexual touching and one count of visual sexual aggression against a child, holding that Defendant received a fair trial with properly admitted expert testimony and a clear guilty verdict.After a third trial, Defendant was convicted and sentenced. On appeal, Defendant argued that the trial court erred in accepting the jury's verdict, that prosecutorial misconduct deprived him of a fair trial, and that the court erred in admitting the State's expert witness's testimony. The Supreme Judicial Court affirmed, holding that the court did not clearly err in finding the State's witness to be a qualified expert witness. View "State v. Westgate" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court granting Pamela Dobbins's motion to enforce the terms of a divorce judgment and a later court order acceptable for processing (COAP) federal retirement benefits, holding that the court lacked the authority to order Mark Dobbins to retire.In the COAP, the court stated that Mark was required to retire at age sixty-two. When Mark turned sixty-two years old, Pamela filed a motion to enforce the divorce judgment and COAP. Mark filed a motion for relief from judgment, arguing that the divorce judgment and COAP were ambiguous and that the court was not authorized to require him to retire at a specific age. The district court denied relief, finding that the divorce judgment and the COAP were enforceable as written. The Supreme Judicial Court vacated the judgment, holding that the court lacked the authority to order Mark to retire at a certain age. View "Dobbins v. Dobbins" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court affirming a decision of the Town of York Board of Appeals purporting to grant Daniel and Susan Raposa's appeal from a decision of the Town's Code Enforcement Officer (CEO), holding that because the Board's written findings of fact directly nullified its decision to grant the appeal, the matter must be remanded for further proceedings.The Raposas contacted the Town's CEO to express their concern that Joshua Gammon's use of his property was not consistent with his predecessor's lawful nonconforming use. The CEO determined that Gammon's operation of his business on his property was not a change in use from his predecessor's use of the property. On appeal, the Board granted the Raposas' appeal as to the change-of-use issue. In the Board's written decision, however, the Board stated, "The use of the lot by Mr. Gammon's landscaping business does not constitute a change of use but is an intensification of the same use." The superior court affirmed, concluding that the Board's written decision was the operative decision for judicial review. The Supreme Judicial Court held that because the Board's written decision contained factual findings directly contradicting its initial decision, the matter must be remanded for further proceedings. View "Raposa v. Town of York" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing, for lack of standing, Appellant's petition to establish de facto parentage of his stepson, holding that Appellant was entitled to a hearing to determine his standing.Appellant filed a petition to be adjudicated the child's de facto parent after the mother died unexpectedly. With the petition, Appellant included an affidavit alleging facts to support the existence of a de facto parent relationship with the child. The court dismissed the petition for lack of standing, concluding that Appellant could not establish a necessary element of standing even if the facts in his affidavit were true. The Supreme Judicial Court reversed, holding (1) Appellant's assertions, if believed, could have led to a find that he had standing; (2) Respondent's affidavit generated disputed material facts that must be resolved to determine Appellant's standing; and (3) the court abused its discretion in refusing to hold an evidentiary hearing to resolve those factual disputes. View "Libby v. Estabrook" on Justia Law