Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the superior court entering summary judgment in favor of Defendants on Plaintiff's complaint alleging attorney malpractice, holding that the court erred in concluding that Plaintiff failed to present evidence of causation to proceed with its legal malpractice claim.Plaintiff submitted an application for site plan review for approval of a commercial facility. The town's planning board approved the application. Abutters to the site appeal the decision to the town's board of appeals (BOA), and Plaintiff hired Defendants to represent it before the BOA. The BOA ultimately reversed the planning board's decision. Plaintiff appealed, but because Defendants failed to file a brief, the appeal was dismissed. Plaintiff then brought this action alleging that it suffered harm due to Defendants' negligence. The court granted summary judgment for Defendants, concluding that Plaintiff could not show either that the planning board's decision would have been upheld or that the BOA's decision would have been overturned absent Defendants' negligence. The Supreme Court vacated the judgment and remanded for further proceedings, holding that the superior court, had it originally reviewed the planning board's decision, would have concluded that the board's approval of the site plan did not reflect error. View "MSR Recycling, LLC v. Weeks & Hutchins, LLC" 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)(i)-(ii), (iv), holding that Father was not denied a fair hearing and that the court did not err by drawing an adverse inference from Father's invocation of his Fifth Amendment privilege.On appeal, Father argued that the district court's judgment violated his due process rights because the court predicated factual findings that he was involved in illegal drug activity in part on his invocation at trial of his constitutional privilege against self-incrimination. The Supreme Judicial Court disagreed, holding (1) Father received a fair hearing; (2) the court did not err by considering evidence of Father history of drug-related criminal conduct and substance abuse, established in part by adverse inferences, as factors that contributed to the determination of parental unfitness; and (3) the court was entitled to conclude that Father was parentally unfit within the meaning of at least one statutory definition of that legal standard. View "In re Child of Scott A." on Justia Law

The Supreme Judicial Court affirmed the judgment of the business and consumer docket dismissing as time-barred Plaintiff's complaint against U.S. Bank, N.A., the servicer of a mortgage she executed to secure a loan, holding that the court correctly dismissed the complaint as untimely filed.Plaintiff fully performed her obligations arising from a transaction in which she borrowed money and executed a mortgage to secure the loan. Four years after her claim accrued, Plaintiff brought this action under Me. Rev. Stat. 33, 551, alleging that U.S. Bank did not fulfill its statutory duty when it came time for the mortgage to be discharged. The business and consumer docket concluded that the claim was subject to the one-year limitation period set forth in Me. Rev. Stat. 14, 858 and was thus time-barred. The Supreme Judicial Court affirmed, holding that the court correctly dismissed the complaint because it was subject to the one-year statute of limitations. View "Denutte v. U.S. Bank, N.A." on Justia Law

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