Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of manslaughter, holding that the trial court did not err in denying Defendant's motions for a judgment of acquittal and for a new trial.On appeal, Defendant argued that the trial court erred by denying his motion for judgment of acquittal and by denying his motion for a new trial based on allegedly improper arguments proffered by the State during its closing argument. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support the conviction; and (2) Defendant did not demonstrate that the trial court erred by allowing the State to refer to Defendant's disability in its closing argument. View "State v. Bilodeau" on Justia Law

The Supreme Judicial Court vacated the portion of the superior court's judgment granting, in part, Defendant's special motion to dismiss Plaintiffs' amended complaint pursuant to Maine's Anti-SLAPP statute, Me. Rev. Stat. 14, 556, holding that the court erred in dismissing Count 1 of the complaint regarding Defendant's service of the notice of claim.Defendant served Plaintiffs with a notice of claim asserting, among other claims, defamation. Defendant did not file a complaint after serving the notice of claim. Plaintiffs later filed a seven-count complaint against Defendant. The superior court granted Defendant's special motion to dismiss as to two of the four counts in the amended complaint and authorized an award of attorney fees to Defendant. The Supreme Judicial Court held (1) Defendant's notice of claim was not petitioning activity as defined in the Anti-SLAPP statute, and therefore, the court erred in dismissing Count 1; and (2) the court did not err in determining that it could award attorney fees to Defendant, and therefore, the cause is remanded for the trial court to decide whether an award of attorney fees is warranted as to the two remaining counts. View "Pollack v. Fournier" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court after a jury found Defendant guilty of burglary and theft by unauthorized taking, holding that the trial court did not commit reversible error.On appeal, Defendant argued that the trial court erred in denying his motion to suppress portions of a surveillance video recording because other portions of the recording were not preserved and that the court committed obvious error by failing to intervene after several allegedly improper comments made by the prosecutor during closing argument. The Supreme Judicial Court affirmed, holding (1) the trial court's finding that the State did not act in bad faith when it failed to preserve the remainder of the recording did not constitute clear error, and therefore, the court did not err when it denied Defendant's motion to suppress; and (2) the majority of the prosecutor's statements challenged on appeal did not rise to the level of misconduct, and as to the remaining statement, the court's instructions clarified any misimpression that the prosecutor's comments may have created. View "State v. Chan" on Justia Law

The Supreme Judicial Court vacated the judgments of conviction for both murder and robbery, holding that the instructions on the elements of robbery misstated the law and thereby also rendered erroneous a portion of the court's instructions on self-defense, requiring a new trial.Defendant was convicted of intentional or knowing murder and robbery. On appeal, Defendant argued that the trial court's jury instructions allowed the State to obtain a conviction without proof of every element of robbery as charged. The Supreme Judicial Court agreed, holding (1) the instructions on the elements of robbery made it possible that the jury reached a verdict based on impermissible criteria; (2) the error in the robbery instruction also affected the judgment of conviction of murder; and (3) the error seriously affected the fairness and integrity of the proceedings and may have affected the verdicts. View "State v. Asante" on Justia Law

The Supreme Judicial Court affirmed the order of the juvenile court placing A.I. in the custody of the Department of Health and Human Services, holding that the juvenile court correctly applied the preponderance of the evidence standard when it determined whether to place A.I. in the custody of the Department.On appeal, Mother argued that the matter should be remanded to the juvenile court so that findings can be addressed under a clear and convincing standard rather than a preponderance of the evidence standard. The Supreme Judicial Court disagreed, holding that A.I.'s dispositional hearing fell on the less-intrusive end of the continuum and that the juvenile court did not err when it applied the preponderance of the evidence standard in the proceedings below. View "State v. A.I." on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court entering summary judgment in favor of State Farm Fire and Casualty Company on the complaint filed by Plaintiffs seeking to reach and apply the State Farm vehicle insurance coverage of a man found jointly and severally liable to Plaintiffs for damages, holding that the facts did not bring Plaintiffs' damages within the policy's coverage.Grover Bragg was driving a truck insured by State Farm to transport an intoxicated and delusional friend when the friend jumped out of the truck, broke into Plaintiffs' house, damaged property, and assaulted one of the plaintiffs. Plaintiffs brought a complaint against Bragg, alleging negligence, and against Bragg's friend. The court concluded that Bragg and his friend were jointly and severally liable to Plaintiffs and awarded damages. The Supreme Court affirmed. Plaintiffs then commenced the present action seeking to reach and apply Bragg's vehicle insurance policy and to obtain a declaratory judgment that the coverage applied. The court entered summary judgment for State Farm. The Supreme Court affirmed, holding that the injuries and property damage suffered by Plaintiffs were not causally connected to the vehicle use in a way that brought them within the insurance coverage. View "Haskell v. State Farm Fire & Casualty Co." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his two children, holding that there was sufficient evidence to support the trial court's finding that Father was parentally unfit and that the court did not abuse its discretion in finding that termination was in the best interests of the children.Specifically, the Supreme Judicial Court held (1) the record contained sufficient evidence for the trial court to find by clear and convincing evidence that Father was unable or unwilling to protect the children from jeopardy or take responsibility for the children within a time reasonably calculated to meet the children's needs or in finding that Father failed to make a good faith effort to rehabilitate and reunify with the children and was therefore unfit to parent the children; and (2) the record contained sufficient evidence for the trial court to conclude that termination was in the children's best interests. View "In re Children of Jason C." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child, holding that the record contained sufficient evidence for the trial court to find by clear and convincing evidence that Mother was unfit and that termination was in the best interest of the child.Specifically, the Supreme Judicial Court held (1) the district court's findings as they relied to Mother's unfitness were supported by the evidentiary record, such as evidence regarding Mother's inability to remain child-focused and her longstanding health issues; and (2) there was neither error nor abuse of discretion in the district court's determination that termination of Mother's parental rights was in the child's best interest. View "In re Child of Louise G." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Parents' parental rights to their three children, holding that the trial court did not commit clear error or abuse its discretion.In terminating Parents' parental rights the trial court concluded that Parents were unwilling or unable to protect the children from jeopardy and that these circumstances were unlikely to change within a time calculated to meet the children's needs and that Parents had been unwilling or unable to take responsibility for the children within a time reasonably calculated to meet the children's needs. The Supreme Judicial Court affirmed, holding (1) the Department of Health and Human Services presented sufficient evidence upon which the trial court could find that Parents were parentally unfit; (2) the trial court did not abuse its discretion in finding that termination was in the children's best interests; and (3) the trial court did not abuse its discretion in questioning Father or any other witness pursuant to Me. R. Evid. 614. View "In re Children of Jamie P." on Justia Law

In this foreclosure action, the Supreme Judicial Court vacated the judgment of the district court entered in favor of Duane Beedle, holding that the court erred in concluding that U.S. Bank, N.A. did not prove that it owned the mortgage and therefore did not have standing to file a foreclosure action.In 2003, Beedle executed a note and mortgage in favor of Fleet National Bank for the purchase of certain property. In 2012, the mortgage was assigned to U.S. Bank, as trustee for Assignee #1. In 2016, Beedle was sent a notice of default. Beedle declared the entire principal amount outstanding. In 2017, a second assignment was executed, by which U.S. Bank claimed that Assignee #1 assigned its interest in the mortgage to U.S. Bank. U.S. Bank subsequently commenced this foreclosure action. The district court entered judgment for the Beedles, concluding that U.S. Bank failed to prove ownership of the mortgage due to a "faulty" 2012 assignment. The Supreme Court vacated the judgment, holding that the 2012 assignment of the mortgage was enforceable. View "U.S. Bank, N.A. v. Beedle" on Justia Law