Justia Maine Supreme Court Opinion Summaries
State v. Catruch
The Supreme Judicial Court affirmed the judgments of the trial court terminating Appellant's participation in the Co-Occurring Disorders and Veterans Court (Veterans Court), holding that the court did not err or abuse its discretion in terminating Appellant's participation in the Veterans Court.The Veterans Court is a criminal docket that provides judicial monitoring, specialized treatment, and other services for military veterans who have disorders often attributable to their military service. Appellant was charged with leaving the scene of an accident and three other offenses. Appellant was admitted to the Veterans Court. Agreeing to sentencing outcomes in a plea agreement and entering into a bail contract, Appellant pleaded guilty to all charges against him. The court later terminated Appellant's participation in the Veterans Court, finding that Appellant had violated the conditions of his bail contract. The Supreme Judicial Court affirmed, holding (1) this matter was properly before the Court; and (2) given Appellant's failure to comply with the requirements for participation in the treatment court and his violations of the agreements, his termination from the Veterans Court was warranted. View "State v. Catruch" on Justia Law
Posted in:
Criminal Law
Watson v. State
The Supreme Judicial Court vacated the judgment of the unified criminal docket denying Appellant's petition for post-conviction review, holding that Appellant was deprived of the effective assistance of counsel when his trial attorney played a video of the ten-year-old victim's interview with police and that Appellant was adversely affected.Appellant was convicted of two counts of gross sexual assault, one count of unlawful sexual contact, and one count of visual sexual aggression against a child. The Supreme Court affirmed. Appellant later filed a petition for post-conviction review claiming that his trial attorney's representation was deficient because introducing the videotaped recording of the victim's entire interview with law enforcement was unnecessary to provide evidence supporting the victim's potential motive to fabricate the allegations. The post-conviction court denied denied the petition. The Supreme Court vacated the judgment below, holding that trial counsel's conduct was deficient and that counsel's actions rose to the level of comprising the reliability of Appellant's conviction and undermining confidence in it. View "Watson v. State" on Justia Law
Posted in:
Criminal Law
Bridges v. Caouette
The Supreme Judicial Court affirmed the judgment of the district court granting Marla Bridges's motion to correct a clerical error in the parties' divorce judgment and denying Christopher Caouette's motion to terminate spousal support, holding that the district court did not err.On appeal, Caouette argued that the district court abused its discretion by concluding that the inclusion of the phrase "or remarries" in a provision of the divorce judgment was a clerical error and by denying his motion to terminate spousal support based substantively on Bridges's remarriage. The Supreme Judicial Court affirmed, holding (1) although the court erred in identifying its decision as a clerical correct, it was clear that the court was interpreting the original divorce judgment and in so doing was acting to grant Bridges's motion to enforce; and (2) the court did not abuse its discretion in denying Caouette's motion to terminate spousal support due to Bridges's remarriage based on its findings regarding the financial situations of both parties. View "Bridges v. Caouette" on Justia Law
Posted in:
Family Law
State v. Lindell
The Supreme Judicial Court affirmed Defendant's convictions of theft by unauthorized taking, theft by deception, securities violations, tax evasion, and failure to pay state income tax, holding that the trial court did not commit prejudicial error or abuse its discretion.Specifically, the Supreme Judicial Court held (1) the court did not abuse its discretion by admitting into evidence employee procedure manuals or certain checks with their memo lines unredacted without a limiting instruction; (2) the court did not err by declining to instruct the jury on the definition of the word “conduct,” by declining to instruct the jury on methods for calculating income taxes, and by failing to provide the jury with relevant statutes; and (3) the court did not err in concluding that Defendant's conduct satisfied the territorial applicability requirement of Maine law. View "State v. Lindell" on Justia Law
Posted in:
Criminal Law
Wilmington Savings Fund Society, FSB v. Abildgaard
The Supreme Judicial Court affirmed the judgment of the superior court in favor of David Abildgaard following a trial on the foreclosure complaint filed by Wilmington Savings Fund Society, FSB, as Trustee for RPMLT 2014-1 Trust, Series 2014-1, holding that Wilmington failed to present evidence at trial of all necessary elements of its foreclosure claim.Abildgaard executed and delivered a promissory note and allonge in favor of Wilmington secured by a mortgage on real property located in Portland. Over a decade later, after Abildgaard defaulted on the loan, Wilmington filed a foreclosure complaint. After a bench trial, the court entered judgment for Abildgaard. The Supreme Judicial Court affirmed, holding that Wilmington failed to present evidence to establish all required elements of its foreclosure claim, and therefore, Abildgaard was entitled to a judgment on the merits. View "Wilmington Savings Fund Society, FSB v. Abildgaard" on Justia Law
Posted in:
Real Estate & Property Law
Mathiesen v. Michaud
The Supreme Judicial Court affirmed the judgment of the divorce between Todd Mathiesen and Karie Ann Michaud entered by the district court, holding that the court did not err in denying Mathiesen's motion for recusal.The trial court issued a divorce judgment that, among other things, awarded primary physical residence of the parties' child to Michaud. On appeal, Mathiesen's sole argument was that the court abused its discretion in denying his motion for recusal. The Supreme Judicial Court affirmed, holding that, under the circumstances of this case, the judge's decision not to recuse himself was proper. View "Mathiesen v. Michaud" on Justia Law
Posted in:
Family Law
In re Estate of Kendall W. Hatch Jr.
The Supreme Judicial Court affirmed the judgment of the probate court interpreting a divorce judgment and ruling that certain real property once held in joint tenancy by Karen Hatch and Kendall Hatch, was an assets of Kendall's estate, holding that the probate court's decision represented a reasonable interpretation of the underlying divorce judgment.Karen appealed the probate court's judgment, arguing that the court erred in holding that the joint tenancy was severed and that Kendell was the sole owner of the property at issue at the time of his death. Rather, Karen contended, the property was still held in joint tenancy at the time of Kendall's death and that she became sole owner by right of survivorship when he died. The Supreme Judicial Court affirmed, holding that the probate court did not err in interpreting the divorce judgment and subsequent orders of the district court in concluding that title to the property vested in Kendall before his death and that the joint tenancy was severed. View "In re Estate of Kendall W. Hatch Jr." on Justia Law
Posted in:
Family Law, Real Estate & Property Law
MSAD 6 Board of Directors v. Town of Frye Island
The Supreme Judicial Court affirmed the judgment of the superior court determining that the Town of Frye Island may not withdraw from Maine School Administrative District 6 (MSAD 6) in the absence of legislation expressly authorizing the Town to invoke the statutory withdrawal process set forth in Me. Rev. Stat. 20-A, 1466, holding that the superior court did not err.The residents of Frye Island voted unanimously to withdraw from MSAD 6. The Legislature responded by enacting L.D. 500, which stated that the Town could not withdraw from MSAD 6 unless withdrawal was first authorized. Frye Island later amended its charter and again sought to withdraw from MSAD 6. MSAD 6 sought a declaratory judgment that Frye Island's effort to withdraw from MSAD 6 was unlawful. The court granted summary judgment for MSAD 6. The Supreme Judicial Court affirmed, holding (1) the amendment to the Town's charter did not expressly or implicitly repeal L.D. 500 by operation of law; (2) L.D. 500 does not violate the Maine Constitution's special legislation clause; and (3) the court did not err in dismissing Frye Island's claims arising under the Due Process Clause and Equal Protection Clause of the United States and Maine Constitutions. View "MSAD 6 Board of Directors v. Town of Frye Island" on Justia Law
Posted in:
Education Law, Government & Administrative Law
Brown v. Compass Harbor Village Condominium Ass’n
The Supreme Judicial Court vacated in part and affirmed in part the lower court's judgment in favor of Plaintiffs and against Compass Harbor Village Condominium Association and Compass Harbor Village, LLC (collectively, Compass Harbor), holding that the court erred in ordering specific performance and entering judgment for Plaintiffs on the claim brought pursuant to the Maine Unfair Trade Practices Act (UTPA), Me. Rev. Stat. 5, 205-A to 2014.Plaintiffs brought suit alleging that Compass Harbor's actions with respect to maintenance and governance of the Association caused their units to lose value. The lower court found that Compass Harbor breached the contracts between it and Plaintiffs, the LLC violated its fiduciary duties to Plaintiffs, and Compass Harbor violated section 207 of the UTPA. The court awarded damages to Plaintiffs and entered an order of specific performance requiring Compass Harbor to abide by its contractual and fiduciary duties in the future. The Supreme Judicial Court vacated the judgment in part, holding (1) the UTPA did not apply in this case; (2) the court did not clearly err in calculating damages; and (3) the court went beyond its discretion in entering an order that would involve the court in continuous supervision of Compass Harbor's performance over an indefinite period. View "Brown v. Compass Harbor Village Condominium Ass'n" on Justia Law
Posted in:
Contracts, Real Estate & Property Law
State v. Hansen
The Supreme Judicial Court affirmed Defendant's conviction and sentence for two counts of unlawful sexual contact, holding that sufficient evidence supported the conviction and that there was no error or abuse of discretion in the proceedings below.After a jury trial, Defendant was found guilty of two counts of unlawful sexual contact (Class B). Defendant was sentenced to ten years' imprisonment on the first count and a consecutive term of ten years, suspended, with five years of probation on the second count. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence to support the convictions; (2) the prosecutor's use of leading questions during the direct examination of the child victim did not violate Defendant's right to a fair trial; (3) testimony by the victim's mother did not violate the first complaint rule; and (4) the sentences imposed were not excessive or disproportionate, and the trial court did not abuse its discretion in imposing consecutive sentences. View "State v. Hansen" on Justia Law
Posted in:
Criminal Law