Justia Maine Supreme Court Opinion Summaries

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

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