Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court as a result of a jury verdict finding Defendant guilty of two counts of manslaughter, two counts of causing a death while operating under the influence, and related charges, holding that the court did not err when it denied Defendant's motion to suppress the results of a warrantless blood draw taken at the scene of a fatal motor vehicle accident.Me. Rev. Stat. 29-A, 2522(2) directs law enforcement officers to test the blood of all drivers involved in a fatal, or likely fatal, motor vehicle accident without any requirement of probable cause before the blood draw. Defendant argued on appeal that the statute is unconstitutional on its face. The Supreme Judicial Court agreed but nonetheless affirmed the trial court's denial of Defendant's motion to suppress, holding (1) Me. Rev. Stat. 29-A, 2522(2) violates the Fourth Amendment because it does not require that law enforcement have consent or probable cause to believe that a driver is impaired before drawing a person's blood; but (2) the trial court correctly denied Defendant's motion to suppress because the "good faith" exception to the exclusionary rule applied to the search. View "State v. Weddle" on Justia Law

The Court of Appeals vacated the disposition imposed by the district court in three juvenile matters, holding that the language in State v. J.R., 191 A.3d 1157 (Me. 2018), could be read to suggest that a court imposing an indeterminate commitment of a juvenile to a Department of Corrections facility must specify a commitment no shorter in duration than up to the juvenile's eighteenth birthday, and the trial court here may have proceeded under such a belief.In this consolidated appeal, P.S. argued that the district court abused its discretion in ordering that he be committed to Long Creek Youth Development Center for an indeterminate period up to age eighteen. The Court of Appeals noted that, once the district court decided to commit P.S. to Long Creek, it may have felt compelled to order him committed up to his eighteenth birthday. The Court then acknowledged that its language in J.R. may have contributed to such a belief and clarified that the language of J.R. does not constrain a juvenile court's discretion to impose a shorter period of indeterminate commitment than up to a juvenile's eighteenth birthday so long as that commitment is for at least one year. Accordingly, the Court vacated the judgment and remanded the matter. View "State v. P.S." on Justia Law

The Supreme Judicial Court affirmed the judgment of divorce in this case, holding that there was no merit in Husband's arguments concerning a premarital agreement and a 401(k) plan Husband created during the marriage and that any error in the district court's consideration of the value of Husband's non marital property in its property distribution was harmless.On appeal, Husband argued that the district court (1) erred by interpreting the parties' premarital agreement as not applicable to the 401(k) plan and by failing to consider his testimony that the 401(k) plan was funded in part with nonmarital property, and (2) abused its discretion by making contradictory findings regarding its consideration of his nonmarital real estate and the debt associated with that property. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that the 401(k) plan was marital property; and (2) any error in the manner of the court's consideration of the value of Husband's nonmarital real property was harmless. View "Dow v. Billing" on Justia Law

In this case involving the report of a neutral investigator - an employee of a law firm and the law firm - retained to provide a report to a governmental entity in a personnel matter, the Supreme Judicial Court held that that the employee and the law firm were protected by the employee immunity provision of the Maine Tort Claims Act (MTCA), Me. Rev. Stat. 14, 8108-8188.Appellee filed a claim alleging that Appellants, a law firm and its nonattorney employee, were negligent and preparing and presenting an investigative report regarding Appellee's conduct while serving as the coordinator of the University of Southern Maine's Multi-Cultural Student Affairs. The district court denied Appellants' special motion to dismiss pursuant to the anti-SLAPP law and denied Appellants' motion asserting immunity pursuant to the MTCA. The Supreme Judicial Court affirmed the order on the special motion to dismiss and vacated the motion to dismiss on MTCA grounds, holding (1) the trial court correctly determined that the investigative report at issue in this appeal did not constitute petitioning activity within the meaning of the anti-SLAPP statute; and (2) because Appellants were performing a governmental function on behalf of a governmental entity, the trial court erred in denying the motion to dismiss based on MTCA immunity. View "Hamilton v. Woodsum" on Justia Law

The Supreme Judicial Court vacated the order of the district court granting the Town of Gorham's motion to enforce a consent decree entered earlier in a land-use dispute, holding that there was not a proper record to support the trial court's findings.The Town filed a land-use enforcement claim in the district court charging Defendants with violations of the Gorham Land Use and Development Code. The parties settled the dispute by agreeing to terms set forth in a consent decree, and the trial court ordered the consent decree to be entered as a judgment. The Town then filed a motion to enforce the consent decree, alleging noncompliance on the part of Defendants. The court granted the Town's motion. The Supreme Judicial Court vacated the judgment below, holding that the court order was not supported by competent evidence in the record. View "Town of Gorham v. Duchaine" on Justia Law

The Supreme Judicial Court dismissed this appeal from the judgment of a single justice of the Supreme Judicial Court denying Appellant's petition for habeas corpus, holding that this appeal presented issues that were moot and that none of the exceptions to the mootness doctrine applied.Appellant was charged with multiple juvenile offenses. The district court ordered him held at Long Creek Youth Development Center while awaiting trial. The proceedings were suspended when Appellant was determined to be incompetent to stand trial. Thereafter, Appellant filed a petition for habeas corpus seeking release from Long Creek. The single justice denied the petition. Appellant appealed. Before oral argument, Appellant was released from Long Creek and placed in a residential treatment facility, and the charges against him were dismissed. The Supreme Judicial Court dismissed the appeal, holding that the appeal was moot and that none of the exceptions to the mootness doctrine applied. View "A.I. v. State" on Justia Law

The Supreme Judicial Court affirmed the judgments of the probate court terminating Father's parental rights to his two children in anticipation of adoptions, holding that the evidence was sufficient to support the court's findings that Father was an unfit parent and that termination of his parental rights was in the children's best interests.Mother and Stepfather of the children filed petitions to adopt the children. Thereafter, Mother filed petitions to terminate Father's parental rights, thereby freeing the children for adoption. The probate court subsequently entered judgments terminating Father's parental rights pursuant to Me. Rev. Stat. 18-A, 9-204(b) and Me. Rev. Stat. 22, 4055(1)(A)(2), (B)(2)(a), and (B)(2)(b)(ii). The Supreme Judicial Court affirmed, holding (1) the evidence supported the court's findings of unfitness and that termination of Father's parental rights would be in the children's best interests; (2) any mistake by the court in arranging its findings within the termination orders was not obvious error; and (3) the court did not err by failing to consider open adoptions that would have left Father's parental rights intact. View "Adoption by Stefan S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court awarding child support to Father's sister (Aunt), holding that the court properly awarded child support to Aunt but erred in establishing its start date for Mother's past support obligation to Aunt.On appeal, Mother argued that the court erred in awarding past and ongoing child support to Aunt and in its calculation of Mother's income for purposes of child support. Mother further argued that child support should not have been ordered to begin on a date before the divorce complaint was filed. The Supreme Judicial Court held (1) the court did not err in its calculation of Mother's income for purposes of child support; (2) the court did not err in determining that it would be in Child's best interest to order Mother to pay child support, including past support, to Aunt; and (3) the Court erred in ordering child support to begin on a date before Mother commenced the divorce proceeding. View "Winn v. Martel" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his child, holding that the court did not err in terminating Father's parental rights or violate Father's constitutional rights.In terminating Father's parental rights the court found that Father was unable to take responsibility for the child within a time reasonably calculated to meet the child's needs and that termination of his parental rights was in the child's best interest. The Supreme Judicial Court affirmed, holding (1) the district court did not err in finding Father unfit or in determining that termination of Father's rights was in the child's best interest; and (2) the trial court did not commit obvious error in measuring the length of time Father needed to protect the child from jeopardy against the time within which the time should achieve permanency. View "In re Child of Corey B." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court dismissing for lack of standing Uncle and Aunt's family matter complaint seeking a determination of de facto parentage as to Child, holding that the district court did not err in concluding that Uncle and Aunt lacked standing.The paternal aunt and uncle of Child sought a determination of de facto parentage while a child protection matter was pending with respect to Child. The district court granted Uncle and Aunt's motion to intervene in the child protection matter and dismissed for lack of standing their family matter complaint seeking to establish de facto parentage. The Supreme Court affirmed, holding that the facts did not compel a finding, by a preponderance of the evidence, that Uncle and Aunt satisfied all necessary elements for establishing standing to seek de facto parentage. View "In re Child of Philip S." on Justia Law