Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court entering a protection from harassment order against Defendant on the complaint of Jane Doe, holding that the court did not err in issuing the protection from harassment order.Specifically, the Court held (1) the district court did not abuse its discretion in consolidating the hearing on Defendant's motion to dissolve the temporary protection from harassment order and the final hearing on Doe's complaint; (2) the district court did not abuse its discretion in issuing a scheduling order that limited the time for the consolidated hearing to two hours; and (3) the district court did not err in finding credible the testimony of two witnesses and in finding that Defendant intentionally sought to harass Doe. View "Doe v. Plourde" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his children pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i)-(ii), holding that the court did not impermissibly consider Father's incarceration in reaching its parental unfitness determination and that Father failed properly to raise his claim of ineffective assistance of counsel at the termination hearing.Specifically, the Court held (1) the lower court's findings were supported by competent record evidence and, given these findings, the court did not err in finding that Father was unfit; and (2) because Father raised his ineffective representation claim on direct appeal without submitting an affidavit, Father's ineffective representation claim must be denied. View "In re Children of Matthew G." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child and the district court's denial of Mother's motion for relief from that judgment, holding that the court did not err or abuse its discretion.On appeal, Mother challenged the court's parental unfitness and best interest determinations and argued that the court erred in denying her motion for relief based on alleged ineffective assistance of Mother's counsel. The Supreme Judicial Court affirmed, holding (1) there was competent evidence to support the court's finding that Mother was parentally unfit, and the court did not commit clear error or abuse its discretion in determining that termination of Mother's parental rights was in the child's best interest; and (2) the evidence supported the court's determination that Mother did not meet her burden to show that she received ineffective assistance of counsel. View "In re Child of Shaina T." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for manslaughter entered after a jury trial, holding that any error in admitting certain testimony and in challenged remarks made by the prosecutor during closing argument did not require reversal of the conviction.Specifically, the Court held (1) Defendant failed to preserve for review her objection to the admission of certain testimony, and a challenged statement by another witness was not unfairly prejudicial; (2) certain misstatements made by the State during its closing argument did not rise to the level of prosecutorial misconduct; (3) the evidence was sufficient to support the conviction; (4) the trial court did not abuse its discretion in denying Defendant's motion for voir dire and a new trial based on allegations of juror misconduct; and (5) Defendant's sentence is constitutional. View "State v. Scott" on Justia Law

In two consolidated land-use matters the Supreme Judicial Court vacated an order entered by the superior court denying a motion for contempt filed by several individuals (the individuals) against the Town of Arundel and others and granting the Town's motion for sanctions in the form of a vexatious litigant order (VLO), holding that the individuals were not properly before the court.The Town filed two complaints against Dubois Livestock, Inc. and Cynthia Dubois (collectively, the Dubois entities) alleging land-use laws violations. The parties agreed to a consent order resolving the issues. One year later, the individuals, who were not parties in the underlying case, filed a motion seeking a contempt order against the Town, the Arundel Planning Board (APB), and individual members of the APB, asserting that they had violated the consent order. The Town moved for sanctions in the form of a VLO against the individuals and the Dubois entities. The superior court denied the motion for contempt and entered a VLO against the individuals. The Supreme Judicial Court vacated the judgment below, holding (1) the individuals had no standing to file the motion for contempt; and (2) because the individuals were earlier dismissed as parties to this appeal, the VLO must be vacated as well. View "Town of Arundel v. Dubois Livestock, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a), (1)(B)(2)(a)-(b)(i), holding that there was no clear error or abuse of discretion in the court's findings or analysis.On appeal, Mother argued that the court erred in finding by clear and convincing evidence that she was an unfit parent after determining that she would be unable to protect the child from jeopardy within the statutorily-required timeframe. The Supreme Judicial Court disagreed, holding that the trial court's conclusion that the child had waited long enough for permanency was well supported by the record. View "In re Child of Amey W." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his child pursuant to Me. Rev. Stat. 4055(1)(B)(2)(a), (b)(ii), holding that the court did not err or abuse its discretion by concluding that terminating Father's parental rights was in the child's best interest.The district court based its best interest determination primarily on the child's need for permanency. On appeal, Father did not challenge the court's factual findings or its determination of parental unfitness. Instead, Father asserted only that the court erred by concluding that termination of his parental rights was in the child's best interest. The Supreme Judicial Court affirmed, holding that the court did not err or abuse its discretion by concluding that terminating Father's parental rights was in the child's best interest. View "In re Child of Scott L." on Justia Law

The Supreme Judicial Court affirmed the judgment of divorce entered by the district court after a contested hearing and the court's denial of Father's post-judgment motions to alter or amend the judgment or for a new trial, holding that there was no error in the court's factual findings or any abuse of discretion in its awarding primary residence of the parties' minor child to Mother and establishing a gradually increasing contact schedule for Father.On appeal, Father argued that because the trial judge recused himself sua sponte after the judgment was entered, there may have been undue prejudice by the judge due to the judge's participation in other proceedings involving Father. The Supreme Court affirmed, holding that the record provided no support for Father's claim that the trial judge erred in failing to recuse himself sua sponte during the trial. The Court remanded the matter for further proceedings on Mother's request for attorney fees. View "Schafer v. Schafer" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of theft by unauthorized taking of a firearm and other offenses, holding that the evidence was sufficient to support the convictions and that the court did not err in admitting certain testimony pursuant to the excited utterance exception to the hearsay rule.Specifically, the Court held (1) the evidence was sufficient to support Defendant's conviction of unlawful possession of scheduled drugs; (2) the evidence was sufficient to support Defendant's convictions for theft of a firearm and domestic violence criminal threatening; and (3) the trial court did not err by admitting a witness's testimony regarding statements Defendant's girlfriend made to him after Defendant left the house upon concluding that those statements qualified as excited utterances. View "State v. Curtis" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for burglary, stealing drugs, and violation of a condition of release, holding that the trial court did not err when it denied Defendant's motion to suppress al evidence obtained as a result of the State's acquisition of Defendant's cell phone's location information (CSLI).Specifically, the Supreme Court held (1) because Defendant lacked standing to challenge evidence obtained as a result of the acquisition of a coperpetrator's CLSI, which was the same evidence Defendant sought to exclude based on the acquisition of his own CSLI, this Court need not decide whether the acquisition of Defendant's CSLI was a search under the Fourth Amendment; (2) whether the State violated Defendant's rights under Maine's Electronic Device Location information Act, 16 Me. Rev. Stat. 647 to 650-B, was irrelevant to whether the court erred in denying Defendant's motion to suppress; and (3) the entry into and search of Defendant's residence were lawful. View "State v. O'Donnell" on Justia Law