Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's and Mother's parental rights to their child, holding that the court did not err or abuse its discretion.Specifically, the Supreme Court held (1) there was sufficient evidence to support the district court's findings of the parents' parental unfitness; (2) the district court did not commit clear error or abuse its discretion in determining that termination of the parents' parental rights was in the child's best interest; (3) the rehabilitation and reunification efforts made by the Department of Health and Human Services were sufficient; and (4) the court did not abuse its discretion by admitting out-of-court statements made by the parties' child. View "In re Child of Nicholas W." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's and Father's parental rights to their children, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Judicial Court held (1) competent evidence in the record supported the court's finding that both parents in his case were parentally unfit; (2) the court did not commit clear error or abuse its discretion in determining that termination of both parents' parental rights was in the best interests of the children; and (3) the court did not err in finding that the Department of Health and Human Services had made reasonable efforts to reunify and rehabilitate Father's family, despite the Department's failure to create a written plan for Father. View "In re Children of James B." on Justia Law

The Supreme Judicial Court vacated in part the judgment of the district court determining Father's and Mother's parental rights and responsibilities as to their son, holding that the court must clarify or amend its findings as to Mother's gross income.In its judgment, the district court awarded Mother primary physical residence of the parties' child and set Father's continuing child support obligation. The Supreme Judicial Court vacated the judgment in part, holding (1) because the judgment contained no explanation of how the court determined Mother's gross income, the matter is remanded for the district court to consider the apparently undisputed evidence about Mother's receipt of fringe benefits and to justify or amend its calculation of Mother's gross income; (2) the court did not err in calculating Father's gross income by imputing income to him during his period of incarceration; and (3) because the court must clarify or amend its findings as to Mother's gross income, the portion of the judgment pertaining to attorney fees is also vacated. View "McLean v. Roberston" on Justia Law

The Supreme Judicial Court vacated the judgment of the probate court denying L.'s petition for termination of his adult guardianship, holding that the court applied an incorrect standard of proof in contravention of Me. Rev. Stat. 18-A, 5-307(d).In denying L.'s petition the probate court determined that L. "failed to prove by clear and convincing evidence that his adult guardianship was no longer necessary for his safety and well-being." The Supreme Court vacated the judgment, holding (1) Me. Rev. Stat. 18-A, 5-307(d) sets forth the burden of proof applicable to L.'s petition for termination of guardianship; and (2) the probate court in this case failed to apply the proper statutory standard of proof in denying L.'s petition. View "In re Adult Guardianship of L." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault, holding that the evidence was sufficient to support the trial court's finding that Defendant possessed the requisite mens rea.On appeal, Defendant argued that Me. Rev. Stat. 17-A, 253(2)(M) must be read to require proof that he knew that the person with whom he was engaging in a sexual act had not expressly or impliedly acquiesced to the sexual act and that the evidence was insufficient to support a finding that he knew the victim had not expressly or impliedly acquiesced to the sexual activity. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support a finding that Defendant engaged in a sexual act that he knew the victim had not expressly or impliedly acquiesced to. View "State v. Asaad" on Justia Law

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