Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions but remanded the case for resentencing, holding that the prosecutor did not engage in misconduct during opening statements but that the trial court erred by imposing a sentence within the enhanced range provided by the version of Me. Rev. Stat. Ann. 17-A, 1252(2)(A) that became effective on September 29, 1995.After a jury trial, Defendant was convicted of three counts of gross sexual assault of a person under the age of fourteen and two counts of unlawful sexual contact. The trial court sentenced Defendant to twenty-four years' imprisonment, all but sixteen years suspended, with probation for six years. Defendant appealed. The Supreme Judicial Court affirmed, holding (1) Defendant failed to demonstrate obvious error in the prosecutor's act of alluding to Defendant's supposed confession in his opening statement without ever presenting testimony to support that contention; and (2) Defendant's right to a jury trial was violated when the trial court enhanced the penalty for Defendant's crime beyond what was statutorily authorized after finding an additional fact not pleaded and proved to the jury. View "State v. Pelletier" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Plaintiff's complaint for legal malpractice as untimely pursuant to Me. Rev. Stat. 14, 752, 753-B, holding that the court-made doctrines of continuing representation and continuing negligence do not apply in the determination of the date on which a cause of action for legal malpractice accrued under section 753-B.On appeal, Plaintiff argued that its legal malpractice claim was not barred because the doctrines of continuing representation and continuing negligence operate to bring the date of the act or omission giving raise to its injury within the relevant statute of limitations. The Supreme Judicial Court declined to adopt either doctrine in the context of actions for attorney malpractice, holding that the superior court correctly dismissed the complaint as barred by Maine's six-year statutes of limitations for civil actions and attorney malpractice actions. View "Packgen, Inc. v. Bernstein, Shur, Sawyer & Nelson, P.A." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court modifying certain provisions of the parties' divorce judgment relating to parental rights and responsibilities, holding that any judicial error was harmless.On appeal, Appellant argued that the district court erred by admitting into evidence a report submitted by the guardian ad litem (GAL) after the court had excused the GAL from being present during the hearing. Specifically, Appellant argued that he was prevented him from cross-examining the GAL about her report. The Supreme Judicial Court affirmed, holding that, assuming that Appellant was entitled to challenge the admission of the GAL report despite his failure to object, it was highly probable that the admission into evidence of the report did not prejudice Appellant or materially contribute to the court's ultimate determination. View "Banks v. Leary" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on Plaintiff's claims alleging age discrimination, retaliation, breach of contract, and various other torts, holding that there was no error or abuse of discretion in the superior court's handling of Plaintiff's requested accommodations.On appeal, Plaintiff argued that the trial court abused its discretion by not, sua sponte, granting him accommodations, appointing him a guardian ad litem, or ordering that his mental health be evaluated. The Supreme Judicial Court disagreed, holding (1) the court did not err by granting summary judgment in favor of Defendants on all of Plaintiff's claims; and (2) the court properly handled Plaintiff's request for accommodations. View "Gallagher v. Penobscot Community Healthcare" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Appellants' motions for judgment as a matter of law and a new trial following a jury verdict in favor of Appellee on his claims for breach of contract, breach of fiduciary duty, and fraudulent misrepresentation, holding that the superior court did not err.Specifically, the Court held that the superior court did not err by (1) allowing Appellee to proceed on a claim of fraudulent misrepresentation based upon allegation that Appellants did not intend to perform their obligations under the contract at the time it was executed; (2) failing to give a requested jury instruction; and (3) allowing Appellee to proceed on a claim for breach of fiduciary duty when the parties' relationship was governed by a limited liability company operating agreement. View "Cianchette v. Cianchette" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Appellants' claim for a declaratory judgment in this zoning dispute, holding that the superior court did not err in dismissing the claim as duplicative of Appellants' appeal from a municipal action that was included in the same complaint.Appellants owned a parcel of land that abutted a parcel owned by Landowners. After the zoning board of appeals (ZBA) approved Landowners' application for permission to raze an existing house located on their property and to build a new one Appellants filed a complaint against the Town of Cape Elizabeth and Landowners, asserting, inter alia, a request for judicial review of the ZBA's approval of Appellants' application pursuant to Me. R. Civ. P. 80B and an independent claim for a declaratory judgment that section 19-6-11(E)(2) of the Cape Elizabeth Zoning Ordinance is preempted by the state's Mandatory Shoreland Zoning Act, Me. Rev. Stat. 38, 439-A(4)(C)(1). The superior court dismissed the declaratory judgment claim as duplicative of the Rule 80B appeal. The Supreme Judicial Court affirmed, holding that because Appellants' claim for declaratory relief was not independent from its Rule 80B, the superior court's dismissal of the declaratory judgment claim as duplicative was not an abuse of discretion. View "Cape Shore House Owners Ass'n v. Town of Cape Elizabeth" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered by the superior court in favor of Spectrum Medical Group and one of its radiologists on Michael and Debra Holmeses' medical malpractice claims, as well as the court's judgment for Eastern Maine Medical Center and one of its surgeons on this same claims, holding that the Holmeses did not make out a prima facie case for negligence.On appeal, the Holmeses argued that there was evidence in the record upon which a fact-finder could reasonable decide that the negligent reading of a critical CT scan caused delay in necessary treatment and that this delay was a proximate cause of Michael's injuries. The Supreme Judicial Court disagreed, holding that the the record presented was insufficient to provide any basis for a determination that the reading of the CT scan played a role in Michael's injuries. View "Holmes v. Eastern Maine Medical Center" on Justia Law

The Supreme Judicial Court vacated in part the judgment of the district court granting Mark Klein a divorce from Jessica Demers, setting parental rights and responsibilities between them as to their minor child and denying Mark's motion for further findings of fact, holding that the court's judgment did not contain adequate factual findings to support its conclusions.Specifically, the Court held (1) the court's judgment did not contain the express factual findings that were necessary to support its conclusion that allocation of final decision-making authority to Demers and limitations on Klein's contact was in the best interest of the child; and (2) therefore, the court abused its discretion by denying Klein's motion for further findings of fact. View "Klein v. Klein" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence (OUI), holding that the court did not err in concluding beyond a reasonable doubt that Defendant had operated a motor vehicle while intoxicated, in violation of Me. Rev. Stat. 29-A, 2411(1-A)(A).On appeal, Defendant argued that there was insufficient evidence for the court to have found, beyond a reasonable doubt, that Defendant operated a motor vehicle while under the influence. The Supreme Judicial Court disagreed, holding that the court's findings were supported by competent evidence in the record that was sufficient to allow a fact-finder to rationally conclude beyond a reasonable doubt that Defendant operated a motor vehicle while under the influence. View "State v. Bittues" on Justia Law

The Supreme Judicial Court affirmed the sentences entered by the trial court in connection with Defendant's plea of guilty to two murders and a dozen other crimes, holding that the court did not err in imposing two life sentences.The Supreme Court imposed a life sentence for each of the two murders and concurrent sentences of various terms of years for the other crimes. On appeal, Defendant argued that court erred in sentencing him because, in setting the base sentences, the court improperly considered the other crimes that Defendant committed at the time of the murders. Further, Defendant argued that the court improperly double-counted his criminal history. The Supreme Judicial Court affirmed, holding (1) the court engaged in the proper considerations during the sentencing analysis; and (2) the court's recognition of Defendant's violent and dangerous conduct at the time of the murders was neither a misapplication of legal principles nor an abuse of discretion. View "State v. Lord" on Justia Law