Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court dismissing Mark Belliveau's complaint for divorce from Janet Whelan because the parties were never legally married, holding that the court did not err by declining to adopt the putative spouse doctrine or the doctrine of marriage by estoppel.For twenty-six years, the parties in this case held themselves out to be a married couple. Belliveau ultimately filed a complaint for divorce. Whelan sought to dismiss the complaint, asserting that the parties were never legally married. The court agreed with Whelan and dismissed the complaint. The Supreme Judicial Court affirmed after declining Belliveau's request that the Court adopt one, or both, of two equitable doctrines, holding (1) the parties did not comply with the statutory requirements to enter into a valid marriage; and (2) the adoption of either the putative spouse doctrine or the doctrine of marriage by estoppel would be an infringement on the Legislature's function. View "Belliveau v. Whelan" 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 district court did not err in determining that Father was parentally unfit and that termination of Father's parental rights was in the best interest of the child.After a hearing, the district court found by clear and convincing evidence that Father was unwilling or unable to protect the child from jeopardy or take responsibility for the child within a time that is reasonably calculated to meet the child’s needs and determined that termination of Father’s rights was in the best interest of the child. The Supreme Judicial Court affirmed, holding that the court did not abuse its discretion in its findings. View "In re Child of Walter C." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his child, holding that competent record evidence supported the court's findings of parental unfitness and that termination of Father's parental rights was in the child's best interest.After a hearing, the district court concluded that the State had proved by clear and convincing evidence that Father was parentally unfit pursuant to three of the statutory definitions of unfitness and that termination of Father's parental rights was in the best interest of the child. The Supreme Judicial Court affirmed, holding that there was sufficient evidence to support the court's determinations. View "In re Child of Nathaniel B." 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 evidence was sufficient to support the court's findings of parental unfitness and its determination that termination of Mother's parental rights was in the child's best interest.The district court terminated Mother's parental rights on the grounds that Mother was unable to protect the child from jeopardy and was unable to take responsibility for the child in a time reasonably calculated to meet the child's needs and that termination was in the child's best interest. The Supreme Judicial Court affirmed, holding that there was sufficient evidence in the record to support the court's findings of parental unfitness and that termination of Mother's parental rights was in the child's best interest. View "In re Child of Rebecca J." on Justia Law

The Supreme Judicial Court affirmed the judgment of the probate court appointing Donovan C's maternal aunt as his full guardian, holding that the probate court did not erred by finding that Father abandoned the child and did not abuse its discretion by appointing the aunt as a full guardian.After Mother died, the maternal grandfather and maternal aunt filed a petition to be appointed as the child's co-guardians. The probate court found by clear and convincing evidence that Father had abandoned the child and that it was in the best interest of the child for the maternal aunt to be appointed as his guardian. The Supreme Judicial Court affirmed, holding (1) there was no error in the probate court's finding of abandonment; and (2) the probate court did not abuse its discretion in appointing the maternal aunt as a full guardian, as opposed to a limited guardian, without implementing transitional arrangements. View "In re Guardianship of Donovan C." on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of murder but finding him guilty of felony murder and robbery in connection with a drug-related homicide, holding that Defendant's conviction for both felony murder and the underlying felony of robbery violated the constitutional protection from double jeopardy.Specifically, the Court held (1) the trial court did not err, while exercising its gatekeeping function, by declining to admit certain hearsay statements because the admission of those statements would have run contrary to the truth-seeking function of Me. R. Evid. 804(b)(3); and (2) although Defendant did not raise the double jeopardy issue in the trial court, the State acknowledged that Defendant's convictions for both robbery and felony murder violated the double jeopardy clauses of the state and federal constitutions, and therefore, the case must be remanded for further post-trial proceedings to eliminate the double jeopardy effect arising from the two charges. View "State v. Armstrong" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for murder, holding that that trial court erred by excluding evidence of Defendant's guilty plea to the murder charge but that the error was harmless.Specifically, the Supreme Judicial Court held (1) the court erred by excluding certain evidence purporting to show that Defendant's friend was responsible for the murder, including evidence that Defendant's friend had pleaded guilty to murdering the same victim, but the error was harmless because of the magnitude and strength of the State's evidence; and (2) the sentence of sixty-five years in prison was constitutional and did not violate either the Eighth Amendment to the United States Constitution or Me. Const. art. I, 9, and the sentence was proportionate, even for someone who, like Defendant, was eighteen years old when he was arrested. View "State v. Dobbins" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court on a complaint filed by Thornton Academy and residents of Arundel (collectively, Plaintiffs) in connection with the decision of Regional School Unit 21 and its Board (collectively, RSU 21) not to allow Arundel middle school students to attend Thornton Academy at public expense, holding that the court did not misinterpret Me. Rev. Stat. 20-A, 1479.In their complaint, Plaintiffs sought a declaratory judgment that RSU 21 incorrectly interpreted and applied Me. Rev. Stat. 21-A, 1479 in deciding that all Arundel public middle school students must attend the Middle School of the Kennebunks and that public funds cannot be used for those students to attend Thornton Academy. The superior court concluded that, pursuant to Me. Rev. Stat. 21-A, 1479(3)(A), RSU 21 must continue to allow Arundel middle school students to attend Thornton Academy at public expense. The Supreme Judicial Court affirmed, holding that section 1479(3)(A) requires RSU 21 to provide the option for Arundel middle school students to attend Thornton Academy at public expense. View "Thornton Academy v. Regional School Unit 21" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Plaintiff's complaint alleging professional malpractice and related causes of action arising from Defendant's legal representation of him in federal criminal proceedings, holding that the complaint failed to state a claim for relief.Defendant was appointed to represent Plaintiff in criminal proceedings on the charge of failure to register as a sex offender. Plaintiff admitted that he did not dispute that he failed to register, and the court sentenced him to a term of months and a period of supervised release with conditions. Later, in probation violation proceedings, Plaintiff admitted that he had violated the conditions of his supervised release. Plaintiff was sentenced, and his conviction was affirmed on appeal to the federal district court. Plaintiff later filed this civil complaint against Defendant, alleging legal malpractice and related claims arising from Defendant's representation of him both at sentencing for failure to register and during the proceedings to revoke his supervised release. The superior court dismissed the complaint for failure to state a claim. The Supreme Judicial Court affirmed, holding that the complaint was properly dismissed for failure to state a claim. View "Goguen v. Haddow" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court denying Petitioner's petition for review of a final agency action and affirming a disciplinary action that resulted in the imposition of sanctions against him for the offense of assault, holding that the record contained no competent evidence to support the hearing officer's determination that Petitioner committed an assault.The hearing officer determined that Petitioner was guilty based on the report of a corrections officer. The Chief Administrative Officer affirmed the hearing officer's decision. The superior court denied Petitioner's petition for review of the agency action and affirmed the disciplinary action. The Supreme Judicial Court vacated the judgment below, holding (1) Petitioner's right to call witnesses was not unreasonably restricted; but (2) Petitioner demonstrated that no competent evidence existed to support the hearing officer's determination. View "Carryl v. Department of Corrections" on Justia Law