Justia Maine Supreme Court Opinion Summaries

Steven Edwards was convicted by a jury of eighteen counts of possession of sexually explicit material involving minors under 12 years old. The charges stemmed from images found on his computer during a search executed with a warrant. Edwards challenged the court's decisions on several motions, including a motion to suppress evidence, arguing the warrant was based on stale information, and motions for judgment of acquittal, mistrial, and a new trial.The Somerset County court denied Edwards's motion to suppress, finding that the information supporting the warrant was not stale. The court noted that the Maine State Police Computer Crimes Unit had received multiple tips from the National Center for Missing and Exploited Children about uploads from Edwards's IP address. The court also found that consumers of child pornography often retain such material for long periods, supporting the warrant's issuance.At trial, the court heard testimony from law enforcement and forensic experts. Edwards moved for a judgment of acquittal, arguing insufficient evidence that he possessed or accessed the images with intent to view them. The court denied the motion, and the jury found Edwards guilty on all counts. Edwards's post-trial motions for a mistrial and a new trial were also denied, despite his argument that the prosecutor's comments during closing arguments were prejudicial.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's decisions. The court held that the information supporting the search warrant was not stale and that there was sufficient evidence for the jury to find Edwards guilty. The court also found that the trial court's curative instruction was adequate to address any potential prejudice from the prosecutor's comments, and there was no abuse of discretion in denying the motions for a mistrial and a new trial. View "State of Maine v. Edwards" on Justia Law

Matthew A. Dennis was convicted of possession of a firearm by a prohibited person and violation of a condition of release following a jury-waived trial. The case arose when Officer Seth Burnes responded to a report of a disturbance at 68 Elm Street, where Dennis, who was under bail conditions to avoid contact with the victim, was found arguing with the victim. During the incident, Dennis was seen with a jacket containing a black-powder pistol, which appeared to have been fired. Dennis was arrested and charged accordingly.The trial court (Penobscot County, A. Murray, J.) denied Dennis's motion to suppress evidence and proceeded with a bench trial. During cross-examination, it was revealed that the pistol had been test-fired by police six days before the trial, and this information had been uploaded to the ShareFile platform used for discovery. Dennis's counsel argued that the late disclosure was unfair and requested dismissal or exclusion of the evidence. The court found no discovery violation but acknowledged the late disclosure and allowed Dennis to review the test-firing video and offered the opportunity to conduct his own test-firing, which Dennis declined.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that there was no discovery violation as the test result was provided within two days of its existence and before the trial. The court found that the trial court's remedy, which included allowing Dennis to review the test-firing video and offering the opportunity for his own test, was appropriate and did not deprive Dennis of a fair trial. The court concluded that the trial court's actions sufficiently mitigated any potential prejudicial effect of the late test-firing. View "State of Maine v. Dennis" on Justia Law

Pedro Rosario was convicted of aggravated trafficking of scheduled drugs in 2021 and sentenced to twenty-five years in prison, with ten years suspended, four years of probation, and a $25,000 fine. His conviction was affirmed by the Maine Supreme Judicial Court in 2022. In April 2023, Rosario filed a motion to vacate the judgment and for a new trial, alleging that a juror was improperly seated and biased. The State accepted the allegations as true for the purposes of the motion.The trial court held a non-testimonial hearing and found that during jury selection, Rosario’s counsel wanted to voir dire Juror 23, but another juror was brought forward by mistake. Juror 23 was selected as an alternate but was mistakenly seated as a juror when another juror was dismissed. Rosario’s attorney did not object at the time. Later, Rosario’s attorney discovered that Juror 23 had attended high school with the District Attorney but had not spoken to him since. The trial court determined that this information was not newly discovered evidence and denied Rosario’s motion for a new trial.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that Rosario’s motion was untimely under M.R.U. Crim. P. 33, as the information about Juror 23 was known before the trial concluded. The court also found no evidence of juror bias or misconduct that would warrant a new trial. The court concluded that Rosario received a fair trial by an impartial jury and upheld the trial court’s judgment. View "State of Maine v. Rosario" on Justia Law

In this case, the defendant was convicted of gross sexual assault and unlawful sexual contact involving an eleven-year-old victim who frequently visited the defendant's home. The defendant admitted to engaging in sexual acts with the victim during a police interview. The defendant was charged by criminal complaint and later by indictment, to which he pleaded not guilty.The trial court denied the defendant's motions to suppress his statements made during the police interview, determining that he was not in custody and that his statements were voluntary. The court found that the interview was non-custodial, conducted in a conversational manner, and that the defendant was informed he could leave at any time. The court also found no evidence that the defendant's hearing issues rendered his statements involuntary.During the trial, the jury heard testimony from the victim and the detective, and the court admitted the recorded interview and text messages between the defendant and the victim. The prosecutor made statements during closing arguments about the victim's credibility and the meaning of emojis in the text messages, which the defendant argued were improper. The court provided curative instructions to the jury regarding the prosecutor's statements.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The Court held that the trial court did not err in denying the motions to suppress, as the defendant was not in custody and his statements were voluntary. The Court also found that any prosecutorial errors during closing arguments were harmless and did not affect the defendant's substantial rights. The judgment of conviction was affirmed. View "State of Maine v. Farley" on Justia Law

Ernest B. Weidul was convicted of manslaughter and other charges in 2012. He later filed a petition for post-conviction relief, alleging that he had received ineffective assistance of counsel. The justice who presided at Weidul’s trial and during the first two days of the post-conviction hearing retired before the hearing was completed, and a different justice presided during the third day of hearing and rendered a judgment denying the petition. Weidul appealed, arguing that the judgment should be vacated because the justice who rendered it did not observe the testimony of the witnesses who testified during the first two days of the hearing and did not permit Weidul to recall those witnesses except for questioning on areas not covered previously.The lower courts had denied Weidul's petition for post-conviction relief. The justice who presided over the first two days of the post-conviction hearing retired before the hearing was completed, and a different justice presided over the third day of the hearing and rendered the judgment denying the petition. Weidul appealed this decision, arguing that the second justice should not have been able to make a judgment without observing the testimony of the witnesses who testified during the first two days of the hearing.The Maine Supreme Judicial Court agreed with Weidul, stating that there is no provision in the rules of procedure authorizing a justice who did not preside during disputed live testimony during a post-conviction hearing to adjudicate the credibility of the testimony over objection. The court found that the error was not harmless and vacated the judgment, remanding the case for additional proceedings. View "Weidul v. State" on Justia Law

The case involves Moosehead Mountain Resort, Inc. (the Resort) and the State of Maine. In 1986, the State sold a ski area, along with easements and a portion of the abutting parcel, to the Big Squaw Mountain Corporation (BSMC). The deed included restrictive covenants prohibiting timber harvesting and requiring the continued public use of the ski area. In 1995, the Resort acquired the property, including the restrictive covenants. The Resort later closed half of the ski area and harvested timber from the area, actions which the State argued violated the covenants.The Superior Court of Kennebec County granted summary judgment to the State, finding that the Resort had breached both covenants. The court ordered the Resort to pay damages for the timber harvested and to place funds into an escrow account for the repair and reopening of the ski area.The Resort appealed, arguing that the State could not enforce the covenants as it did not own a parcel that benefited from them, that the court erred in its interpretation of the public use covenant, and that the court erred in granting summary judgment because the public use covenant was unreasonable, the State failed to notify the Resort of its alleged breach, and the State was barred from enforcing the covenant by the doctrine of laches.The Maine Supreme Judicial Court affirmed the lower court's decision. The court held that the State could enforce the covenants without owning a benefiting parcel, that the public use covenant required the Resort to make reasonable efforts to keep the whole ski area open for public use, and that the doctrine of laches did not apply as the Resort had not shown that the State's delay in enforcement was unreasonable or resulted in prejudice to the Resort. View "State v. Moosehead Mountain Resort, Inc." on Justia Law

The case involves Ricky Whitney, who was convicted for sexual exploitation of a minor. Whitney had sent messages to a minor, soliciting her to send explicit photographs. The minor, disturbed by the request, showed the messages to her mother, who then took over the conversation, pretending to be the minor. The mother sent a stock photo of a girl in shorts to Whitney, who then sent additional messages soliciting explicit photographs. The court found that the minor did not see these additional messages.The trial court in Penobscot County, Maine, found Whitney guilty of sexual exploitation of a minor and sentenced him to five years in prison. The court also revoked Whitney's probation in a separate matter and imposed the remaining five years of his suspended sentence, to run concurrently with the sentence for the conviction of sexual exploitation of a minor. Whitney appealed, arguing that the evidence was insufficient to support the conviction because the court did not find beyond a reasonable doubt that the minor received the solicitation to send explicit photographs.The Maine Supreme Judicial Court agreed with Whitney. The court found that the statute under which Whitney was convicted requires proof that the person being solicited is actually under the age of sixteen. The court stated that it is not sufficient that a defendant intended to solicit a minor; he must solicit a person who is in fact a minor. Because the trial court explicitly stated that it could not find beyond a reasonable doubt that the minor received the solicitation, an element of the offense was missing. Therefore, the court found there was insufficient evidence to find beyond a reasonable doubt that Whitney committed the crime of sexual exploitation of a minor. The court vacated the judgment of conviction and remanded the case for entry of a judgment of acquittal. View "State v. Whitney" on Justia Law

The case involves a dispute over the Town of Bar Harbor's decision to present several proposed changes to its municipal charter as separate questions to voters, rather than as a single package. The changes were recommended by a charter commission and included modifications to various areas of the town's governance. A group of voters, led by Michael Good, challenged this approach, arguing that the changes were not "minor modifications" and should have been presented as a single "revision" of the charter.The Superior Court (Hancock County, Anderson, J.) agreed with Good and nullified the changes, ruling that they were not minor modifications and should have been presented as a single revision. The court also found procedural irregularities in how the changes were developed and submitted.On appeal, the Maine Supreme Judicial Court disagreed with the lower court's interpretation. The court held that the charter commission acted legally in determining that its recommendations constituted minor modifications and proposing that they be submitted to the voters in nine separate articles. The court also found that none of the claimed procedural irregularities nullified the vote. Therefore, the court vacated the lower court's judgment and remanded the case for the court to enter a judgment for the Town on Good’s complaint. View "Good v. Town of Bar Harbor" on Justia Law

In this case, a couple, Joseph R. and his wife, sought to adopt the wife's two minor children and terminate the parental rights of the children's biological father. The mother had been granted sole parental rights and responsibilities in a 2016 divorce judgment, and the biological father, who resides in Scotland, had not had contact with the children or the mother since the divorce. The couple married in 2017 and filed their petitions for adoption, change of name, and termination of parental rights in the York County Probate Court in April 2023.The York County Probate Court dismissed the couple's petitions, concluding that it lacked subject matter jurisdiction due to recent legislative changes. Specifically, the court cited the enactment of 19-A M.R.S. § 1658(1-A) in 2021, which it interpreted as giving exclusive jurisdiction to the District Court in cases involving one parent's attempt to terminate another parent's parental rights to a minor child. The couple appealed this decision.The Maine Supreme Judicial Court disagreed with the lower court's interpretation of the statute. The court noted that the Probate Court has exclusive jurisdiction over petitions for adoption and termination of parental rights proceedings brought pursuant to section 9-204. The court found that the language in section 1658(1-A) does not divest the Probate Court of subject matter jurisdiction in this matter. The court further examined the legislative history of section 1658 and concluded that section 1658(1-A) applies only to termination petitions brought pursuant to 19-A M.R.S. § 1658 and does not divest the Probate Court of its subject matter jurisdiction over termination petitions filed in conjunction with adoption proceedings under 18-C M.R.S. § 9-103. Therefore, the court vacated the judgment and remanded the case for further proceedings. View "Adoption by Joseph R." on Justia Law

The case revolves around Delanna Garey, who was employed as the director of operations of an apartment building managed by Stanford Management until her termination in January 2023. In February 2023, Stanford and its current director of operations, Eve Dunham, requested the Rumford Police to serve Garey with a criminal trespass notice, barring her from entering the building for a year. In March 2023, Stanford and Dunham posted copies of the criminal trespass notice on the building and sent a letter to the residents stating that former employees were not permitted on the premises. Garey filed a complaint against Stanford alleging defamation, false light invasion of privacy, and reckless or intentional infliction of emotional distress, and seeking declaratory judgment and injunctive relief.The Superior Court granted Stanford’s motion to dismiss Garey’s complaint in its entirety, concluding that Garey failed to state claims upon which relief could be granted. The court reasoned that Stanford’s statements were not provably false; they were statements of opinion, not of fact; the statements were subject to multiple interpretations and should not be attributed their worst possible meaning; and in the alternative, even if the statements were defamatory, they were conditionally privileged.Upon review, the Maine Supreme Judicial Court concluded that Garey met her burden and vacated the Superior Court judgment with respect to her claims for defamation per se and false light invasion of privacy. The court affirmed the dismissal of her claims for declaratory judgment and injunctive relief as moot. The court found that Garey’s complaint sufficiently alleged that Stanford published statements that falsely imply that Garey engaged in dangerous conduct such that the community needs protection. The court also concluded that Garey has sufficiently alleged a claim for false light invasion of privacy. However, Garey’s declaratory judgment and injunctive relief claims were moot because she is no longer precluded from entering the building property. View "Garey v. Stanford Management, LLC" on Justia Law