Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed in part and vacated in part Defendant's judgment of conviction of gross sexual assault, unlawful sexual contact, sexual abuse of a minor, and unlawful sexual touching, holding that there was insufficient evidence to support the convictions of gross sexual assault and unlawful sexual contact.The Supreme Judicial Court remanded the case for resentencing, holding (1) there was sufficient evidence to support Defendant's convictions for sexual abuse of a minor and unlawful sexual touching; and (2) because the State did not present any evidence that Defendant, a substitute teacher, possessed the requisite authority over the victim, a student, at the time that he committed the sexual act and sexual contact, there was insufficient evidence to convict Defendant of gross sexual assault and unlawful sexual contact. View "State v. Conroy" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court finding that Mother and Father's child was in jeopardy pursuant to Me. Rev. Stat. 22, 4035, holding that there was no error in the proceedings below.Specifically, the Court held (1) the district court did not err in applying the presumption in Me. Rev. Stat. 22, 4035(2-A) regarding Father's prior convictions for sex offenses against children, nor did it impermissibly shift the burden of proof to the parents in violation of their due process rights; and (2) the district court's ultimate determination, by a preponderance of the evidence, of jeopardy was not clearly erroneous. View "In re Child of Ryan F." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court finding that Mother's child was in circumstances of jeopardy to the child's health or welfare and ordering that the child remain in the custody of the Department of Health and Human Services, holding that Mother's due process right was not violated and that the court's factual findings were not clearly erroneous.Specifically, the Court held (1) in the proceedings below, there was no error, obvious or otherwise, that deprived Mother of a fair trial or resulted in a substantial injustice; and (2) contrary to Mother's argument, the district court's supported findings established as more likely than not that returning the child to Mother's custody would cause the child serious harm or the threat of serious harm. View "In re Child of Brooke B." on Justia Law

The Supreme Judicial Court affirmed the judgment of the probate court denying Appellant's petition for formal adjudication of intestacy and appointment of personal representative of the estate of her former husband, David Washburn, on behalf of their minor son, holding that the probate court did not err.Specifically, the Court held (1) the probate court did not err in finding that David Washburn had sufficient testamentary capacity to execute a valid will; and (2) the probate court did not err by determining that there was no evidence that could sustain a finding of undue influence by a clear and convincing evidence standard. View "In re Estate of Washburn" on Justia Law

The Supreme Judicial Court affirmed Defendant's judgment of conviction of two counts of stalking and two counts of harassment entered by the trial court after a jury trial, holding that the court did not err or abuse its discretion.Specifically, the Court held (1) the trial court did not violate Defendant's right to a fair trial; (2) the judgment entered in Defendant's favor in a prior protection from harassment matter was not entitled to res judicator effect in this criminal prosecution; (3) the trial court did not err when it allowed one of the victims to testify that a lawsuit Defendant filed against the victim was dismissed with prejudice; (4) the trial court did not err in denying Defendant's motions for judgment of acquittal; and (5) the trial court committed no obvious error in failing to give three jury instructions. View "State v. Williams" on Justia Law