Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court in favor of Spurwink Services, Inc. on the claim filed by Sydney and Patricia TerMorshuizen for overtime pay pursuant to Me. Rev. Stat. 26, 664, holding that interruptions to "sleep time" are not compensable under section 664.The TerMorshuizens worked as a therapeutic couple at Spurwink's day and residential treatment program for children and adolescents with significant emotional and behavioral needs. The TerMorshuizens, who lived in the residence with the children, brought suit seeking overtime wages, arguing that, while Spurwink paid them for sleep time interruptions, they were entitled to payment for other client interruptions that prevented them from sleeping, regardless of whether those interruptions actually required direct client interaction. The trial court granted summary judgment for Spurwink on the grounds that Spurwink's sleep time compensation policy was in compliance with federal law and was reasonable as a matter of law. The Supreme Judicial Court affirmed, holding that the superior court did not err in (1) applying section 29 C.F.R. 785.23 to determine whether sleep time constitutes compensable work time; and (2) determining that Spurwink's sleep time policy was reasonable as a matter of law. View "TerMorshuizen v. Spurwink Services, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child, holding that Mother had a right to the effective assistance of counsel at the proceeding where she consented to the termination of her parental rights and that Mother received effective assistance when she voluntarily gave her consent.At a hearing, Mother advised the court that she had decided to consent to a termination of her parental rights. Satisfied that Mother's decision was knowing and voluntary, the court ordered that Mother's parental rights be terminated. Mother later filed a motion for a new trial pursuant to Me. R. Civ. P. 59, arguing that her consent was involuntary and that she had received ineffective assistance of counsel in giving consent. The court denied Mother's request to set aside her consent. Mother also filed a Me. R. Civ. P. 60(b)(6) motion for relief from the termination judgment based on counsel's alleged ineffective assistance. The court denied the motion. The Supreme Judicial Court affirmed, holding that the court did not clearly err in finding that Mother voluntarily consented to a termination of her parental rights or in denying the Rule 60(b)(6) motion for relief without holding a second evidentiary hearing. View "In re Child of Rebecca J." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of aggravated criminal mischief and did not reach the State's claim of error on cross-appeal, holding that the evidence was sufficient for the jury to rationally find and conclude that the State proved each element of the offense of aggravated criminal mischief beyond a reasonable doubt.On appeal, Defendant argued that the State had not proved that he had damaged the "property of another" - a critical element of aggravated criminal mischief. On cross-appeal, the State challenged the denial of its motion to correct the sentence because the court did not order restitution. The Supreme Judicial Court affirmed, holding (1) the jury rationally could have inferred that Defendant intentionally, knowingly, or recklessly caused damage to the property of another; and (2) because the State failed to file an appeal and obtain the written approval of the Attorney General to appeal the court's decision, this Court did not reach the State's claim of error. View "State v. Ouellette" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for failure to sign a criminal summons, refusing to submit to arrest by physical force, and assault, holding that the trial court abused its discretion by excluding from evidence a cellphone video taken by the defendant's sister that showed some of the events that occurred during Defendant's arrest.Specifically, the Court held (1) because the trial court did not rely on Me. R. Evid. 403 when excluding the video at issue and because the video was properly authenticated, the court's refusal to admit the video so that the jury could view it was an abuse of discretion; and (2) the trial court's exclusion of the video was not harmless error. View "State v. Hussein" 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 pursuant to Maine's Child and Family Services and Child Protection Act, 22 Me. Rev. Stat. 4001 to 4099-H, and the Indian Child Welfare Act (ICWA), 25 U.S.C.S. 1901-1963, holding that the district court did not err in terminating the parents' parental rights and denying their other requests for relief.Specifically, the Court held (1) the district court did not err by concluding that active efforts had been made to prevent the breakup of the Indian family, as required by ICWA; (2) the evidence was sufficient to support the court's determination that Mother was parentally unfit within the meaning of state law; (3) the district court did not err in denying Father's two motions to transfer the case to the Penobscot Nation Tribal Court; and (4) the district court did not err in denying Father's post-judgment motion alleging ineffective assistance of counsel. View "In re Child of Radience K." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review alleging ineffective assistance of counsel in his probation revocation matter but that Appellant may file a motion for a new probation revocation hearing in the trial court within thirty-five days of the issuance of this mandate.The trial court concluded that Appellant's remedy for any claim of error arising from the revocation was to seek a discretionary appeal, as Appellant had already done. The Supreme Judicial Court held (1) in a probation revocation hearing, a defendant has a right to the effective assistance of counsel; (2) Appellant's motion was properly dismissed, but Appellant was deprived of an opportunity to obtain meaningful review on his claim; and (3) a defendant who seeks to raise a claim of ineffective assistance of counsel after a probation revocation hearing may do so by filing a motion under Rule 33 of the Maine Rules of Unified Criminal Procedure for a new trial, which must be filed thirty-five days after the entry of judgment, and the judge who issued the revocation judgment will, if the defendant has made out a prima facie claim of ineffective assistance, will hold an evidentiary hearing or dismiss the motion. View "Petgrave v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying Appellant's motion to modify the parties' divorce judgment and her mother for the court to reconsider that order, holding that the district court did not err in its judgment.On appeal, Appellant argued that the court summarily dismissed the guardian ad litem's report, testimony, and recommendations regarding primary residency and that the court erred by denying Appellant's motion for reconsideration. The Supreme Judicial Court held (1) the record evidence did not compel the court to conclude that it would be in the child's best interest to reside primarily with Appellant; (2) the court did not abuse its discretion by denying Appellant's motion for reconsideration; (3) the court did not "summarily dismiss" the court-appointed guardian ad litem's testimony; and (4) Appellant's contention that the court's analysis was incomplete was without merit. View "Roalsvik v. Comack" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her three children, holding that the court properly determined that Mother was parentally unfit and that termination of her parental rights was in the best interests of the children.The district court terminated Mother's parental rights pursuant to Me. Rev. Stat. 22. 4055(1)(B)(2)(a), (b)(i)-(ii). The Supreme Judicial Court affirmed, holding (1) the record supported the court's finding that Mother was parentally unfit and that termination of her parental rights was in the children's best interests; and (2) the court did not abuse its discretion in its ultimate decision to terminate Mother's parental rights. View "In re Children of Jessica D." on Justia Law

The Supreme Judicial Court vacated the judgment of the district court modifying the terms of Appellant's divorce from Appellee as to parental rights and responsibilities for the parties' two children, holding that the district court erred in determining that the parties agreed to the terms of the modified divorce judgment.After the parties divorced, they both moved to modify the judgment as to parental rights and responsibilities. The parties and the guardian ad litem then engaged in a judicial settlement conference, after which the court stated that an agreement was reached. The court then entered a judgment purporting to memorialize that agreement without creating any record that would show the terms of any such agreement and the parties' confirmation of it. Appellant moved for relief from the judgment, arguing that the judgment did not accurately reflect the parties' agreement. The court denied the motion. The Supreme Judicial Court vacated the judgment below, holding that, in the absence of a factual record from which to determine whether the modified divorce judgment accurately reflects the parties' agreement, the court's findings that the parties reached a full agreement were clearly erroneous. View "Bahn v. Small" 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)(B)(2)(a), (b)(i)-(ii), (iv), holding that the standard of proof in termination of parental rights cases is constitutionally adequate.On appeal, Mother argued that parental unfitness be proved beyond a reasonable doubt and that the statutory standard burden of proof of clear and convincing evidence was constitutionally insufficient. The Supreme Judicial Court disagreed, holding (1) there is no reason to overturn precedent holding that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases; and (2) the court acted within its discretion in terminating Mother's parental rights. View "In re Child of Shayla S." on Justia Law