Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated Defendant's conviction for violating a condition of release, holding that the trial court lacked subject matter jurisdiction over Defendant's prosecution because the violation occurred in New Hampshire.Defendant was indicted for violating a condition of release. Defendant challenged the court's subject matter jurisdiction on the grounds that his alleged violation occurred outside Maine. The trial court determined that it had jurisdiction and found Defendant guilty. The Supreme Judicial Court vacated the judgment, holding that Maine lacked jurisdiction to prosecute Defendant on a charge of violating a condition of release for his conduct in New Hampshire. View "State v. Sloboda" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing or depraved indifference murder and gross sexual assault, holding that there was no error in the proceedings below.Specifically, the Court held (1) the trial court did not err by failing, sua sponte, to transfer venue based on the pretrial publicity about the case; (2) there was sufficient competent evidence on which a jury could reasonably find, beyond a reasonable doubt, that Defendant committed each element of both crimes; and (3) the trial court did not misapply any legal principles or abuse its discretion in imposing Defendant's sentence as to either crime. View "State v. Keene" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in favor of Tucker Cianchette and CBF Associates, LLC (collectively, Tucker) and against Peggy Cianchette, Eric Cianchette, PET, LLC and Cianchette Family, LLC (collectively, Peggy and Eric) on Tucker's claims against Peggy and Eric and on Peggy and Eric's counterclaim against Tucker, holding that the superior court did not err in clarifying that post-judgment interest began to run on March 15, 2018.In this second appeal before the Supreme Court, the parties sought resolution of two legal issues regarding post-judgment interest: (1) whether the trial court had jurisdiction to issue an order on post-judgment interest, and (2) on what date prejudgment interest ceased and post-judgment interest began to accrue. The Supreme Judicial Court held (1) the trial court had authority to act and did not abuse its discretion in clarifying its judgments to resolve the parties' uncertainty surrounding post-judgment interest; and (2) post-judgment interest did not begin to run until the court entered the final judgment on March 15, 2018. View "Cianchette v. Cianchette" on Justia Law

The Supreme Judicial Court affirmed the judgment entered in the Business and Consumer Docket concluding that the Town of Cape Elizabeth's proffered evidence was insufficient to support a finding that the Town's right to accept the "incipient dedication" of a particular portion of land lapsed at common law, holding that the court did not err in its application of the common law lapse standard.Pilot Point, LLC sought a declaratory judgment that the Town's right to accept the incipient dedication of a portion of Surf Side Avenue (the "Pilot Point Section") had lapsed at common law (count one) and, alternatively, that the Town's right was limited by the scope of the original dedication (count two). The court granted the Town's motion for judgment as a matter of law on count one and dismissed count two as unripe. The Supreme Judicial Court affirmed, holding that the trial court did not err (1) in determining that the evidence was insufficient as a matter of law to establish that the Town's right to accept the dedication of the Pilot Point section had lapsed at common law; and (2) in dismissing without prejudice count two as unripe for judicial review. View "Pilot Point, LLC v. Town of Cape Elizabeth" on Justia Law

The Supreme Judicial Court affirmed the order of the district court committing M. to involuntary hospitalization for up to 120 days, holding that the evidence was sufficient to support the court's decision to order M.'s involuntary hospitalization.The district court authorized M.'s hospitalization for up to 120 days, and the superior court affirmed. On appeal, M. argued that she was denied due process and a fair appeal because there was no verbatim transcript of her commitment hearing and that the record contained insufficient evidence to support the court's findings. The Supreme Judicial Court affirmed, holding (1) the opportunities afforded to M. to supplement the incomplete transcript were sufficient to satisfy due process; and (2) there was sufficient evidence to support the district court's decision. View "In re Involuntary Commitment of M." on Justia Law

The Supreme Judicial Court vacated the portion of the judgment of divorce denying Sarah Teske's request to change her name and otherwise affirmed the judgment, holding that the court's rationale for denying the name change was erroneous.Tegan Teske filed a complaint for divorce from Sarah. Sarah filed an answer and counterclaim but did not request that the court change her name. Before a final hearing, each party submitted a proposed judgment to the court. Sarah's proposed judgment included a provision changing her name to her former name, Sarah Chagnon. The court subsequently entered a divorce judgment that did not change Sarah's name. The Supreme Judicial Court remanded with instructions to amend the judgment to provide that Sarah Teske's name be changed to Sarah Chagnon, holding that the trial court erred in not granting Sarah's request to change her name to her former name. View "Teske v. Teske" on Justia Law

The Supreme Judicial Court vacated the trial court's judgment on remand after Defendant successfully argued that his two convictions of felony murder and robbery violated his right to be free from double jeopardy, holding that the trial court erred by allowing the State to dismiss the robbery count on remand rather than merging it into the felony murder count.On remand, instead of the trial court merging the counts, the robbery count was dismissed by the State. The Supreme Judicial Court vacated the judgment, holding (1) when a trial results in multiple verdicts for the same offense, the appropriate procedure to prevent a double jeopardy violation is to merge, not dismiss, the duplicative counts; and (2) the trial court's failure to hold a new sentencing hearing on remand and conduct a new sentencing analysis pursuant to Me. Rev. Stat. 17-A, 1602 deprived Defendant of a substantial right. View "State v. Armstrong" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Town of Casco Zoning Board of Appeals in which the Board denied the request for a shoreline zoning permit filed by Mark and Valerie Tomasino, holding that the Tomasinos lacked standing to seek such a permit.On appeal, the Tomasinos argued that the Board erred in determining that they demonstrated insufficient right, title, or interest in the property to obtain a permit to remove three trees from property owned by Lake Shore Realty Trust, the abutting property owner, over which the Tomasinos claimed a deeded easement. The Supreme Judicial Court affirmed, holding that, even assuming that the Tomasinos demonstrated that they had some interest in the particular portion of property at issue in this case, they failed to demonstrate that they had the kind of interest that would allow them to cut the trees if they were granted a permit to do so. View "Tomasino v. Town of Casco" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court in favor of Lisa Berry following a bench trial on the complaint for foreclosure filed by Wilmington Trust, National Association, as Trustee for MFRA Trust 2014-2 (Wilmington), holding that the district court did not err.Specifically, the Supreme Judicial Court held (1) the district court did not err by excluding evidence of business records showing Berry's payment history with various loan services because the business records were untrustworthy; (2) Wilmington failed to prove that Berry received a properly served notice of default and mortgagor's right to cure; and (3) the district court did not abuse its discretion in awarding attorney fees to Berry. View "Wilmington Trust, National Ass'n v. Berry" on Justia Law

In this action for recovery of personal property the Supreme Judicial Court vacated in part the judgment of the district court finding Kathryn Colton in contempt and imposing a jail sentence and ordering her incarceration, holding that the district court violated Colton's right to due process by ordering her to be incarcerated without an opportunity to "show cause" in some fashion.Debbie Silverwolf, a former tenant on Colton's property, brought an action against Colton for recovery of personal property. The court entered judgment in favor of Silverwolf and ordered Colton to return the property. When Colton failed to do so the judge held Colton in contempt and ordered her incarceration. No show cause proceeding was held. The Supreme Judicial Court remanded the case for a show cause hearing, holding (1) the court did not err in finding Colton in contempt, and the court's factual findings were supported by the evidence; and (2) the court denied Colton the opportunity to show cause, notwithstanding her attempt to make an offer of proof. View "Silverwolf v. Colton" on Justia Law