Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court finding that Mother's child was in circumstances of jeopardy, holding that the evidence was sufficient to support the court's finding that the child was in jeopardy.The Department of Health and Human Services sought a child protection order for the child alleging that the child was at risk of serious harm due to Mother's volatility and her lack of safe and stable housing. After a hearing, the court determined that the child was in circumstances of jeopardy. The Supreme Judicial Court affirmed, holding that the court did not err in finding that returning the child to Mother's custody would subject the child to a threat of serious harm. View "In re Child of Jasmine B." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of depraved indifference murder pursuant to Me. Rev. Stat. 17-A, 201(1)(B), holding that the State presented sufficient evidence such that the fact-finder could have found each element proved beyond a reasonable doubt.Specifically, the Supreme Judicial Court held (1) the trial court did not err in finding Defendant guilty of murder because the State presented sufficient evidence to support the fact-finder's determination that the State had proved each element beyond a reasonable doubt; and (2) the trial court did not err or abuse its discretion when it limited Defendant's cross-examination of the State's Chief Medical Examiner. View "State v. Gatto" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i)-(ii), (iv), holding that competent evidence supported the court's finding that Mother was parentally unfit and the court's conclusion that termination of Mother's parental rights was in the child's best interest.On appeal, Mother argued that there was insufficient evidence to support the court's findings of at least one ground of parental unfitness and that termination was in the child's best interest. The Supreme Judicial Court affirmed, holding (1) there was competent evidence in the record to support the finding of parental unfitness; and (2) the trial court did not abuse its discretion in concluding that termination of Mother's parental rights was in the child's best interest. View "In re Child of Angela S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court dismissing Appellant's complaint for protection from harassment against Gladys Cassese, holding that Me. Rev. Stat. 5, 4654(1) does not always preclude the court from adjudicating a protection from harassment complaint without first holding a hearing.On appeal, Appellant argued that the court was required to hold a hearing before adjudicating his complaint and that, alternatively, the court erred when it dismissed his complaint for failure to state a claim. The Supreme Judicial Court affirmed, holding (1) a court is not prohibited in all circumstances from dismissing a protection from harassment complaint without first holding a hearing; and (2) the trial court did not err in dismissing Appellant's complaint for failure to state a claim upon which relief could be granted. View "Anctil v. Cassese" on Justia Law

The Supreme Judicial Court affirmed the order of the district court determining that Mother's four children were in circumstances of jeopardy pursuant to Me. Rev. Stat. 22, 4035(2), holding that the evidence was sufficient to support the finding that the children were in jeopardy.After a hearing, the district court determined that the children were in circumstances of jeopardy due to the neglect and infliction of serious injury upon one of the children. The Supreme Judicial Court affirmed, holding (1) the district court did not err in crediting the testimony of one of the expert witnesses of the Department of Health and Human Services over the testimony of Mother's competing expert witness; and (2) the court's findings were sufficient for the court to find that the children would be in circumstances of jeopardy if they were returned to Mother's care. View "In re Children of Alecia M." on Justia Law

The Supreme Judicial Court affirmed the decision of the Business and Consumer Docket affirming a decision of the Secretary of State that validated a direct initiative petition regarding the New England Clean Energy Connect Transmission Project (NECEC), holding that the Secretary of State properly validated the petition.On appeal, Delbert Reed claimed that the Secretary of State erred by (1) validating the petitions notarized by three notaries based on the Secretary of State's misinterpretation and misapplication of Me. Rev. Stat. 21-A, 9030E and Me. Rev. Stat. 954-A, and (2) failing to conduct a more thorough fraud investigation of the initiative campaign's signature-gathering process. The Supreme Court affirmed, holding (1) the Secretary of State did not err by declining, pursuant to sections 903-E and 954-A, to invalidate the petitions that were notarized by the notaries at issue; and (2) the Secretary of State reasonably determined that the broad assertions of fraud were insufficient grounds to launch an additional investigation of the entire campaign. View "Reed v. Secretary of State" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for reckless conduct and aggravated criminal mischief, holding that the trial court did not abuse its discretion by offering Defendant a continuance of the trial in lieu of excluding his medical records.On appeal, Defendant argued that the trial court abused its discretion by denying his motion to suppress his personal medical records as a sanction for the State's late seizure of the records. The Supreme Judicial Court agreed that the State's conduct undermined the purpose of Maine Rule of Unified Criminal Procedure 18(b) but that the court's offer of a continuance in lieu of the exclusion of the evidence constituted an appropriate response to the State's conduct. View "State v. Mullen" on Justia Law

In this commercial forcible entry and detainer action brought by 20 Thames Street LLC and 122 PTIP LLC (collectively, 20 Thames) the Supreme Judicial Court affirmed the judgment of the superior court concluding that the district court lacked subject matter jurisdiction to award lease-based attorney fees upon finding for Ocean State Job Lot of Maine 2017, LLC, holding that the superior court did not err.Ocean State rented a commercial retail space from 20 Thames. 20 Thames later filed its compliant for forcible entry and detainer, alleging that Ocean State breached the terms of its lease. The business and consumer docket found in favor of Ocean State. The court awarded Ocean State costs and $206,076 in attorney fees based on a provision in the lease. The superior route affirmed the judgment for Ocean State but vacated the attorney fee award, concluding that the district court lacked jurisdiction to award lease-based attorney fees. The Supreme Judicial Court affirmed, holding that Me. Rev. Stat. 14, 6017 did not provide authority for the district court to award lease-based attorney fees. View "20 Thames Street LLC v. Ocean State Job Lot of Maine 2017, LLC" on Justia Law

The Supreme Judicial Court vacated in part the judgment of the district court finding that Mother presents jeopardy to her child pursuant to Me. Rev. Stat. 22, 4035, holding that the court miscalculated the date on which the child was considered to have entered foster care.In the jeopardy order, the court found that the child entered foster care on July 4, 2019, a finding to which Mother disagreed. Mother appealed, challenging the date the child was considered to have entered foster care. The Supreme Judicial Court vacated the portion of the jeopardy order containing that finding, holding that September 2, 2019 is the date on which the child was considered to have entered foster care within the meaning of Me. Rev. Stat. 22, 4038-B(1)(B), 4041(1-A), 4052(2-A)(A)(1). View "In re Child of Jillian T." on Justia Law

In this appeal from Defendant's conviction for eleven counts of gross sexual misconduct, the Supreme Judicial Court vacated the judgment of conviction on one count, vacated the dismissal of other counts and remanded for entry of a judgment of acquittal on those counts, and affirmed in all other respects, holding that Defendant's convictions on both Counts 5 and 30 violated his double jeopardy protections and that the court erred in allowing the State to dismiss Counts 27, 28, and 29 during trial without Defendant's consent.The indictment charged Defendant with fifteen counts (Counts 1-13, 30-31) of gross sexual misconduct against the victim and sixteen counts (Counts 14-29) of gross sexual misconduct against a second alleged victim. During trial, the court granted Defendant's motion for a judgment of acquittal on Counts 10-13, and the State dismissed Counts 27-29. Defendant was found guilty of Counts 1-9 and 30-31 and not guilty on the remaining counts. The court entered judgment in accordance with the verdict. The Supreme Judicial Court held that the trial court erred in failing to rule that the Double Jeopardy Clause barred convictions on both Counts 5 and 30 and allowing the State to dismiss Counts 27, 28, and 29 rather than entering a judgment of acquittal on those counts. View "State v. Paquin" on Justia Law