Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Defendant's petition for post-conviction review as untimely filed, holding that, contrary to Defendant's contention on appeal, the court was not precluded from summarily dismissing the petition based on the statutory filing deadline.Defendant pleaded guilty to aggravated trafficking in scheduled drugs and illegal importation of scheduled drugs. Defendant filed a petition for postconviction review seeking to collaterally attack his conviction on the basis of ineffective assistance of counsel. The trial counsel dismissed the petition as untimely filed. On appeal, Defendant argued that the court erred in determining that there is no duty imposed on trial counsel or the sentencing court to inform Defendant about the deadlines for filing a post-conviction review petition. The Supreme Judicial Court disagreed, holding (1) this Court declines Defendant's invitation to impose a new obligation on sentencing courts to inform defendants about the filing deadline set out in Me. Rev. Stat. 15, 2128-B; (2) trial counsel's failure to inform Defendant of the filing deadline for post-conviction review petitions did not constitute ineffective assistance of counsel or preclude enforcement of the filing deadline. View "Roque v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of manslaughter after a conditional guilty plea, holding that the State provided sufficient evidence, independent of Defendant's multiple confessions, to establish corpus delicti for the alleged homicide of Defendant's infant son.On appeal, the Court held (1) the trial court made several factual findings, supported by competent evidence in the record, that were sufficient to establish a substantial belief that the infant's death was a result of criminal agency; and (2) there was no reason to depart from the well-established corpus delicti doctrine and to adopt the federal "trustworthiness" standard. View "State v. Hagar" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying First Financial, Inc.'s motion for relief from judgment after the court denied its motion to dismiss its foreclosure complaint against Peter and Judith Morrison and granted the Morrisons' motion for judgment on the pleadings, holding that the trial court did not err.In their motion for judgment on the pleadings the Morrisons asserted that First Financial's notice of default and the right to cure did not comply with the requirements of Me. Rev. Stat. 14, 6111. First Financial then filed a motion to dismiss its foreclosure complaint without prejudice. The court summarily denied First Financial's motion to dismiss and granted the Morrison's motion for judgment on the pleadings. The Supreme Judicial Court affirmed, holding that where evidence of a properly served notice of default and mortgagor's right to cure in compliance with statutory requirements is an essential element to support a judgment of foreclosure, the court did not err in granting the Morrisons' motion for judgment and denying First Financial's motion for dismissal without prejudice. View "First Financial, Inc. v. Morrison" 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 record contained competent evidence to support the court's findings, by clear and convincing evidence, of both parents' parental unfitness.Specifically, the Court held (1) the court's findings of unfitness were supported by competent record evidence; and (2) the court did not violate Mother's due process rights by denying her motion to continue and then commencing the termination hearing in her absence with the knowledge that she had been arrested, as Mother failed to show that she was prejudiced by her partial absence. View "In re Child of Raul R." 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 determining that termination of Mother's parental rights was in the best interest of her child.After a termination hearing, the court determined that the child's best interest would be served through the permanency plan of adoption. The Supreme Judicial Court affirmed, holding that, given the strength of the record, particularly the length of time the child had been in kinship care and Mother's consistent and demonstrated inability to provide a safe and stable home for the child, the court did not abuse its discretion in concluding that termination of Mother's parental rights was in the child's best interest. View "In re Child of Shannon S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Mother and Father to their child, holding that there was no error in the proceedings below.On appeal, Mother argued that the district court erred in denying her motion for relief from the termination judgment, in which she alleged that she received ineffective assistance of counsel. Father argued that there was insufficient evidence to support the termination of his parental rights. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion by denying Mother's motion for relief from the termination of her parental rights; and (2) there was sufficient evidence in the record to support the court's termination of Father's parental rights. View "In re Child of Dawn B." on Justia Law

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