Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the portion of the superior court's judgment dismissing the declaratory judgment count of Appellants' complaint seeking a declaration that a certain citizen initiative failed to meet the constitutional requirements for inclusion on the November 2020 ballot, holding that the initiative was unconstitutional and could not be submitted to the electors for popular vote.At issue was a citizen initiative that proposed a resolve that would reverse an order of the Maine Public Utilities Commission granting Central Maine Power Company's (CMP) request for a certificate of public convenience and necessity for a 145-mile transmission line. Avangrid Networks, Inc., the company that owned CMP as a subsidiary, filed a complaint leading to the present litigation, seeking a declaratory judgment and injunctive relief. The district court dismissed the complaint, concluding that the initiative's constitutionality was not subject to judicial review before the election. The Supreme Judicial Court vacated the judgment, holding that the initiative failed to meet the constitutional requirements for inclusion on the ballot because it exceeded the scope of the legislative powers conferred by article IV, part 3, section 18 of the Maine Constitution. View "Avangrid Networks, Inc. v. Secretary of State" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant for failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999), Me. Rev. Stat. 34-A, 11227(2), holding that, due to inadequate representation by Defendant's trial counsel, the court committed obvious error by not addressing the constitutionality of SORNA of 1999, as retroactively applied to Defendant.In 1990, Defendant was convicted of four counts of unlawful sexual contact, and in 1992, he was convicted of gross sexual assault. Neither offense required Defendant to register as a sex offender. After the Legislature enacted SORNA of 1999, Defendant 's two convictions became subject to SORNA of 1999. In 2018, Defendant was found guilty of failure to comply with a duty under SORNA of 1999. On appeal, Defendant argued that the retroactive application of SORNA of 1999 to require him to register for life violated the state and federal constitutional prohibitions against ex post facto laws. The Supreme Judicial Court agreed, holding that it could not be said beyond a reasonable doubt that the retroactive application of SORNA of 1999 to Defendant's 1990 and 1992 convictions did not affect his substantial rights by virtue of a punitive alteration of his original sentences. View "State v. Proctor" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs, holding that the the trial court did not commit obvious error in instructing the jury and did not abuse its discretion by denying Defendant's motion for a new trial.Specifically, the Supreme Judicial Court held (1) the trial court did not err in instructing the jury on accomplice liability; (2) the jury instruction on a written report not admitted into evidence was not erroneous; and (3) the court did not abuse its discretion by denying Defendant's motion for a new trial on the basis that statements made during the State's closing argument impermissibly commented upon Defendant's out-of-state residence as evidence of his guilt. View "State v. Plummer" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of murder, holding that the trial court did not abuse its discretion by denying Defendant's motion for a new trial based on newly discovered evidence.Defendant's motion for a new trial was based on a statement allegedly made by his brother in the presence of another individual in which Defendant's brother claimed responsibility for the victim's murder. The trial court denied the motion. The Supreme Judicial Court affirmed, holding that the court did not abuse its discretion in determining that the brother's statement would not be admissible in a new trial and that, even if it were admissible, Defendant failed to establish that the proffered evidence would probably change the result if a new trial were granted. View "State v. Peaslee" on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the superior court denying U.S. Bank Trust, N.A.'s motion to extend the time to file a notice of appeal as to its foreclosure complaint against James D. Keefe, holding that the trial court did not err in denying the motion as untimely.In denying U.S. Bank's motion seeking an extension of time to file its notice of appeal the trial court determined determined that U.S. Bank had shown good cause for the trial court to grant its motion to extend but that its authority to grant an extension of time had expired, and therefore, the motion was untimely. The Supreme Judicial Court affirmed, holding that the trial court did not err in its interpretation of the pertinent Rules of Appellate Procedure or in denying U.S. Bank's untimely motion for an extension of time. View "U.S. Bank Trust, N.A. v. Keefe" on Justia Law

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