Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of manslaughter and aggravated assault, holding that the trial court did not err in instructing the jury and that the evidence was sufficient to support the conviction.On appeal, Defendant argued (1) the trial court erred in denying his request to pose questions regarding self-defense and defense of another in the juror questionnaire, and (2) the evidence was insufficient to support a finding that Defendant's actions - rather than subsequent medical treatment - caused the victim's death. The Supreme Judicial Court affirmed, holding (1) while the court could have included an appropriate question regarding self-defense and defense of another, the court did not abuse its discretion in declining to include such a question; and (2) based on the evidence in there record, the jury could rationally have found beyond a reasonable doubt that the victim's death would not have occurred but for the conduct of Defendant and that the medical care was not clearly sufficient to cause the victim's death. View "State v. Limary" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of Class B theft by deception and one count of Class C theft by deception, holding that there was no error in the proceedings below.On appeal, Defendant argued (1) the trial court erred by failing to include a “nexus” element in its instruction to the jury on the charge of theft by deception, (2) the evidence was insufficient to convict him of theft by deception, and (3) his actions constituted a breach of contract, not a criminal offense. The Supreme Judicial Court affirmed, holding (1) the jury rationally could have found beyond a reasonable doubt each element of theft by deception based on the testimonial and documentary evidence presented at trial and reasonable inferences drawn therefrom; (2) the evidence was sufficient to support the jury's verdict; and (3) Defendant waived his ability to challenge the jury instructions on appeal. View "State v. McLaughlin" on Justia Law

The Supreme Judicial Court vacated in part and affirmed in part a summary judgment entered in the business and consumer docket that adjudicated all claims on the parties' separate, but judicially consolidated, petitions for review of two tax abatement decisions, holding that the court erred in partially abating a portion of certain penalties levied by the State Tax Assessor against Kraft.On appeal, Kraft argued that the lower court erred in determining that it was not entitled to an alternative apportionment of a portion of its 2010 taxable income, that it was not entitled to a full abatement of penalties levied by the Assessor as part of the "first assessment," and that the "second assessment" was not time barred. The Assessor cross-appealed, arguing that the lower court erred in partially abating the substantial understatement penalty levied as part of the first assessment. The Supreme Court (1) affirmed the court's conclusion that Kraft was not entitled to an alternative apportionment; (2) vacated the court's partial abatement of the substantial underpayment penalty because Kraft was not entitled to any abatement; and (3) affirmed the court's determination that the second assessment was not barred by the statute of limitations. View "State Tax Assessor v. Kraft Foods Group, Inc." on Justia Law

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