Justia Maine Supreme Court Opinion Summaries

In this dispute between Beachfront Owners and the Town of Kennebunkport over who held title to disputed portions of Goose Rocks Beach the Supreme Judicial Court affirmed the holding of the trial court that, under the circumstances of this case, legal title to the property was held by the Town for the benefit of the public.The Beachfront Owners sued the Town seeking a declaratory judgment that each of their parcels includes land to the mean low water mark - subject to public rights to fish, fowl, and navigate in the intertidal zone. The Beachfront Owners also sought to quiet title to their alleged breach property. In response, the Town asserted its title to the beach and the dry sand above it and that it and the public had the right to use those areas. The superior court determined that the Town held title - derived from the original Town proprietors' ownership of common land - to the dry sand and beach in front of the majority of the properties in dispute. The Supreme Judicial Court affirmed, holding that title to the disputed land seaward of the seawall, including the beach, was held by the Town for the benefit of the public. View "Almeder v. Town of Kennebunkport" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court denying Beal Bank USA's complaint to compel the assignment of a mortgage to Beal by the insolvent originating lender, New Century Mortgage Corporation, holding that the court did not err in denying the relief sought by Beal to compel assignment of the mortgage in this case.On appeal, Beal argued that because it was the holder of the note secured by the mortgage, the court erred when it failed to apply the equitable trust doctrine to conclude that New Century held the mortgage in trust for Beal and that Beal was entitled to an assignment of the mortgage. The Supreme Judicial Court disagreed, holding (1) although the holder of the note may retain some equitable interest in the accompanying mortgage, any such interest, standing alone, does not equate to actual ownership of the mortgage, nor is the interest sufficient to establish a pre-foreclosure right to compel its assignment; and (2) Beal did not produce sufficient independent evidence of ownership of the mortgage to compel an assignment. View "Beal Bank USA v. New Century Mortgage Corp." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child, holding that the court did not err in finding abandonment and did not err or abuse its discretion in determining that termination of Mother's parental rights was in the child's best interest.On appeal, Mother argued that the court erred as a matter of law in concluding that her failure to appear on the second day of the termination hearing constituted abandonment, in finding that she had the "intent to forego parental duties," and went beyond the scope of a termination proceeding by speculating about who would adopt the child post-termination. The Supreme Judicial Court affirmed, holding (1) the court did not err in finding that Mother had the intent to forego her parental duties and had therefore abandoned the child; and (2) the court acted with in the scope of its authority in speculating that the child would be placed with the great-grandmother. View "In re Child of Olivia F." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating a vehicle when the registration of that vehicle was suspended, holding that the State was not required to provide counsel to Defendant.Defendant was tried before a jury without counsel. The jury returned a verdict of guilty, and the trial court entered a judgment after imposing a fine supplemented by surcharges. Defendant appealed, arguing that he had a right to court-appointed counsel because of his inability or unwillingness to pay a fine and that jury selection proceedings were deficient. The Supreme Judicial Court affirmed, holding (1) because Defendant was not at risk of incarceration as part of the sentence the State was not required to provide counsel; and (2) there was no basis for a claim of legal error or abuse of discretion regarding jury proceedings. View "State v. Lipski" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his two youngest children, holding that Father's due process rights were not violated during the termination proceedings and that the court did not abuse its discretion in concluding that termination of Father's parental rights was in the children's best interests.On appeal, Father argued, among other things, that the district court erred in denying his motion to continue when he was absent during the second day of the termination hearing because he had been arrested shortly before the proceedings began. The Supreme Judicial Court affirmed, holding (1) the resumption of the termination hearing when Father was not present did not deprive him of his right to due process; and (2) the court's best interest determination was well within its discretion. View "In re Children of Benjamin W." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child, holding that the court did not err by finding that Mother was parentally unfit and that termination was in the child's best interest.Specifically, the Supreme Judicial Court held (1) competent evidence supported the court's determination that Mother was parentally unfit; and (2) given the court's proper findings of the child's need for safety, security, and permanency, and Mother's failure to have met those needs, the court did not err in concluding that termination was in the best interest of the child. View "In re Child of Katherine C." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's and Father's parental rights to their child, holding that the court did not err or abuse its discretion in determining that termination of the parents' parental rights would be in the child's best interest.On appeal, Father challenged the sufficiency of the evidence regarding the court's determination that he was unfit, and both parents argued that the court erred in concluding that termination of their parental rights was in the child's best interest. The Supreme Judicial Court affirmed, holding (1) the court did not clearly err by finding that Father was unlikely to become fit within a time reasonably calculated to meet the child's needs; and (2) the court did not abuse its discretion in determining that termination was in the child's best interest where the permanency plan for the child was adoption or a permanency guardianship with the child's grandmother. View "In re Child of Kimberly K." on Justia Law

The Supreme Judicial Court vacated in part and affirmed in part the order of the district court modifying child support and spousal support, holding that there was no error except in the court's calculation of the child support obligation.After James Sulikowski and Sandra Sulikowski divorced Sandra filed a motion to modify child support, alleging that James's income and increased substantially since the divorce. Thereafter, James filed a motion to terminate spousal support, alleging that Sandra's income had increased substantially and that Sandra had been cohabiting in a relationship functionally equivalent to marriage. The court modified James's child support obligation and reduced James's spousal support obligation while ordering Sandra to repay James for his overpayment of spousal support. The Supreme Judicial Court vacated the child support order but otherwise affirmed, holding that, among other things, the court erroneously calculated the weekly child support obligation using the amount listed in the child support table for two children instead of three children but as to the remainder of the order, the district court did not err. View "Sulikowski v. Sulikowski" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing Appellant's compliant alleging revocation of acceptance and breach of warranty as time-barred, holding that the court relied upon facts contained in documents that exceeded the scope of the facts that may be considered by the court in the context of a motion to dismiss.Appellant brought this action alleging claims with respect to a bicycle frame that he purchased that was manufactured by Independent Fabrication, Inc. The district court dismissed the complaint as barred by the four-year statute of limitations set forth in Me. Rev. Stat. 11, 2-725. The Supreme Judicial Court vacated the order of dismissal on procedural grounds and remanded for further proceedings, holding that the court's consideration of matters outside the pleadings in granting Independent's motion to dismiss was in error. View "Greif v. Independent Fabrication, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction of burglary entered by the trial court after a jury trial, holding that the trial court did not err in admitting recordings of incriminating telephone conversations that Defendant had with his girlfriend while he was in jail.A jury found Defendant guilty of burglary. The court sentenced Defendant to one year in prison, with all but sixty days suspended, and a one-year term of probation. On appeal, Defendant primarily challenged the adequacy of the foundation that the State provided to establish the authenticity of the jail recordings. The Supreme Judicial Court affirmed, holding that there was no evidence of tampering and that the court did not err in finding a sufficient foundation for the recordings' admissibility. View "State v. Coston" on Justia Law