Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court vacated the order denying Appellant's motion to dissolve an ex parte attachment entered by the superior court, holding that the court applied an incorrect standard of proof in its order on the motion to dissolve.The Portland Museum of Art (PMA) filed a complaint against Appellant alleging tortious interference with expected inheritance and undue influence and requesting an accounting. The PMA then filed an ex parte motion for attachment and trustee process, which the superior court granted. Thereafter, Appellant unsuccessfully filed a motion to dissolve the attachment and trustee process. The court denied the motion to dissolve, ruling that there was a reasonable likelihood that PMA would recover judgment. The Supreme Judicial Court vacated the order denying the motion to dissolve attachment, holding (1) the court unambiguously articulated the incorrect standard of proof in its order on the motion to dissolve; and (2) the misstatement of the standard was not harmless. View "Portland Museum of Art v. Germain" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of aggravated assault and violating a condition of release, holding that the sanctions imposed on the State were sufficient to remedy the prejudice caused by discovery violations and that there were no other errors in the proceedings below.Specifically, the Court held (1) the court did not abuse its discretion to impose sanctions for the State's discovery violations; and (2) Defendant was not deprived of his Sixth Amendment right to an impartial jury that represented a fair cross section of Defendant's community, and accordingly, the trial court did not err in denying Defendant's motion for a new jury. View "State v. Townes" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review asserting that he had received ineffective assistance of counsel at a probation revocation hearing, holding that the trial court did not err but, as recently announced in Petgrave v. State, __ A.3d ___ (2019), Defendant now has a procedure by which he can pursue his claim.In Petgrave, the Supreme Judicial Court held that a defendant has a right to the effective assistance of counsel at a revocation hearing and that a defendant who contends that he or she received ineffective assistance of counsel at a probation revocation hearing may pursue that claim by filing a properly supported motion for a new trial pursuant to M.R.U. Crim. P. 33. In the instant case, the Court held that Appellant may file a motion for a new revocation hearing in the trial court within thirty-five days following the issuance of the Court's mandate. View "Gould v. State" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing Appellant's complaint seeking to be determined a de facto parent of Appellee's adopted child, holding that the district court erred in dismissing this case for lack of standing.The district court dismissed Appellant's complaint for lack of standing. On appeal, Appellant argued that the district court abused its discretion in refusing to hold a hearing to determine disputed facts and in concluding that Appellee's refusal to allow Appellant to adopt the child was dispositive of the issue of whether Appellee acknowledged or behaved as though Appellant was a parent to the child. The Supreme Judicial Court remanded the case, holding that the court's treatment of the single fact of Appellee's refusal to allow Appellant to adopt as dispositive in the standing analysis constituted an error of law, and the court should have held a hearing to determine disputed facts regarding the issue of standing. View "Young v. King" on Justia Law