Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court denying Mother's post-judgment motions for a new trial and for relief from judgment following the court's entry of a judgment terminating her parental rights to her children, holding that the district court did not abuse its discretion in denying Mother's motions for a new trial and for relief from judgment.The court concluded that the Department of Health and Human Services had met its burden of establishing by clear and convincing evidence that Mother was unwilling or unable to protect her children from jeopardy and that these circumstances were unlikely to change within a time reasonably calculated to meet the children's needs and that Mother was unwilling or unable to take responsibility for the children within a time reasonably calculated to meet their needs. The Supreme Judicial Court affirmed, holding that termination of Mother's parental rights was not premature and that the trial court did not abuse its discretion in denying Mother's post-judgment motions for relief from judgment and for a new trial. View "In re Children of Jessica J." on Justia Law

The Supreme Judicial Court affirmed the order of the district court finding that Father's two children were in circumstances of jeopardy but vacated in part the orders granting two parental rights motions to modify, holding that the court erred, in part, in granting the motions to modify.This consolidated appeal concerned proceedings to determine parental rights and responsibilities and child protection proceedings involving Father, the two children, and the biological mother of each child. The district court entered judgments that (1) found both children were in circumstances of jeopardy; (2) granted a motion to modify an order governing parental rights and responsibilities between Father and the mother of the older child; and (3) granted a motion to modify an amended divorce judgment between Father and the mother of the younger child. The Supreme Judicial Court reversed in part the motions to modify, holding (1) the court did not clearly err in determining that each child was in circumstances of jeopardy; and (2) as to the motions to modify, the court erred by requiring that future contact between Father and each child be dependent upon the recommendation of the child's therapist because this transferred the court's responsibility for determining the best interest of the children. View "In re Children of Richard E." 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), holding that there was sufficient record evidence to support the court's findings of parental unfitness and best interest by clear and convincing evidence.The court terminated Mother's parental rights to the child on the grounds that Mother was unable to protect the child from jeopardy and unable to take responsibility for the child and that these circumstances were unlikely to change in a time reasonably calculated to meet the child's needs. The court further found that termination of Mother's rights was in the child's best interest. The Supreme Judicial Court affirmed, holding that there was no abuse of discretion in the court's determination that the termination of Mother's parental rights was in the child's best interest. View "In re Child of Amber D." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child, holding that competent evidence in the record supported the court's finding that Mother was parentally unfit and that the court did not err in finding that the Department of Health and Human Services had made reasonable efforts to reunify and rehabilitate Mother's family.Based on the evidence before it, the district court found by clear and convincing evidence that Mother met two of the four definitions of parental unfitness. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence to support the court's judgment terminating Mother's parental rights; and (2) the court did not err in finding that the Department had made reasonable efforts to reunify and rehabilitate the family. View "In re Child of Amelia C." on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the district court finding that Mother's child was in circumstances of jeopardy pursuant to Me. Rev. Stat. 22, 4002(6), 4035(2), and ordering the child remain in the custody of the Department of Health and Human Services, holding that the evidence was sufficient to support the court's determination that the child was in jeopardy.On appeal, Mother challenged the sufficiency of the evidence to support the court's finding, by a preponderance of the evidence, that the child was in circumstances of jeopardy. The Supreme Judicial Court affirmed, holding that, taken together, the court's supported factual findings were sufficient to support its determination that the child would be "subject to a threat of serious harm" if he were returned to the custody of Mother. View "In re Child of Whitney M." on Justia Law

The Supreme Judicial Court vacated the judgment of the district court ordering the turnover and sale of Travis Otis's boat satisfy a money judgment against him in favor of Erik Wuori, holding that the court erred in concluding that the boat was not used "primarily for commercial fishing" within the meaning of Me. Rev. Stat. 14, 4422(9) and was therefore not exempt from attachment and execution.The boat at issue was a thirty-six-foot boat that Otis used to catch lobsters for the Maine Department of Marine Resources in order to collect data on juvenile lobsters. The district court concluded that the boat was not exempt from attachment and execution because Otis did not harvest the lobster he caught but, rather, returned them to the ocean. Thus, the court reasoned, Otis did not use the boat "primarily for commercial fishing." The Supreme Judicial Court vacated the judgment, holding that because Defendant's hauling and catching was compensated by the Department, the use of his boat constituted "commercial fishing." View "Wuori v. Otis" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court vacating a Department of Health and Human Services hearing officer's decision requiring AngleZ Behavioral Health Services to pay $392,603.31 in MaineCare reimbursements because of billing errors, holding that the superior court erred by finding that the Department did not submit proper evidence in support of some of its recoupment claims.After auditing the claims submitted by AngleZ between February 13, 2013 and July 20, 2013 The Department issued a notice of violation applying an error rate to all of AngleZ's claims during that time period. The Department ultimately sought a total recoupment of $392,603.31. A hearing officer concluded that the Department was correct in seeking 392,603.31 in recoupment, and the Department's acting commissioner adopted the recommendation. The superior court vacated the Commissioner's decision, concluding that the hearing officer's decision was not supported by substantial evidence. The Supreme Judicial Court vacated the superior court's judgment, holding that the hearing officer's decision was supported by substantial evidence and was neither arbitrary nor capricious. View "AngleZ Behavioral Health Services v. Department of Health and Human Services" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court in favor of Defendants following a bench trial on Plaintiffs' claims against Defendants stemming from Plaintiffs' purchase of Defendants' house, holding that the trial court's factual findings were supported by the evidence and that the court did not err in deciding in favor Defendants.Defendants entered into a purchase and sale agreement with Plaintiffs to sell Defendants' home. After Plaintiffs discovered a number of deficiencies in the house they filed a complaint alleging counts arising from the house's sale and defects. The trial court granted judgment in favor of Defendants. The Supreme Judicial Court affirmed, holding that the trial court's explicit findings were comprehensive, detailed, and adequately supported by record evidence. View "Wuestenberg v. Rancourt" on Justia Law

In this declaratory judgment action contesting the ownership of certain property the Supreme Judicial Court vacated the final judgment entered on behalf of Lisa Yorke finding that Brad Belanger's deed to Rebecca Belanger was not supported by consideration, holding that the trial court did not apply the correct legal standard to resolve the issue of consideration.Brad deeded the property at issue to Lisa, his daughter, before he deeded it to Rebecca, his wife. Rebecca recorded her deed before Lisa recorded hers. Both Lisa and Rebecca claimed exclusive title to the property and sued each other for a declaratory judgment that each woman owned the property. The court found that Brad's deed to Rebecca was not supported by consideration and, therefore, she was not a bona fide purchaser of the property. The court entered final judgment for Lisa. The Supreme Judicial Court vacated the judgment in part, holding (1) the trial court correctly found that Me. Rev. Stat. 33, 480, which requires the signature of a nonowner spouse on a transfer of real property in certain circumstances, was not an affirmative defense to Lisa's ownership claim; and (2) the trial court did not apply the correct legal standard to resolve the issue of consideration. View "Belanger v. Yorke" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered by the superior court in favor of Riverview Psychiatric Center on Plaintiff's complaint alleging a violation of the Whistleblowers' Protection Act, 26 Me. Rev. Stat. 831-840, holding that there were no genuine issues of material fact precluding summary judgment.After Plaintiff was terminated from his employment at Riverview he filed the instant action. The superior court granted Riverview's motion for summary judgment. The Supreme Judicial Court affirmed, holding that there were no genuine issues of material fact regarding whether Plaintiff was entitled to whistleblower protection based on complaints he made about Riverview's staffing policies, his supervisor's alleged mistreatment of another employee, and potential violation of patient confidentiality pursuant to the Health Insurance Portability and Accountability Act. View "Pushard v. Riverview Psychiatric Center" on Justia Law