Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of operating under the influence, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained from a blood draw and that the court's jury instructions were sufficient and appropriate.Prior to trial court, Defendant filed a motion to suppress evidence from the blood draw and the corresponding blood-alcohol test result, arguing that the evidence was obtained without valid consent. The trial court denied the motion. After closing arguments, Defendant requested a curative instruction to remedy the State's alleged misstatement of the evidence in its closing argument. The court declined to give such an instruction. The jury subsequently found Defendant guilty of operating under the influence. The Supreme Judicial Court affirmed, holding (1) Defendant had the capacity to give knowing consent to the blood draw, and his consent was voluntary; and (2) the prosecutor's closing statements to the jury did not misstate the evidence, demonstrate bad faith, or create any prejudice. View "State v. Ayotte" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder, holding that the court did not abuse its discretion by admitting Facebook Messenger records into evidence and that there was sufficient evidence to support the jury's verdict.On appeal, Defendant argued that the court erred in admitting Facebook Messenger records because they were not properly authenticated and that they were improperly admitted pursuant to the hearsay exception that allows for the admission of a declarant's statement of his then-existing statement of mind. The Supreme Judicial Court affirmed, holding (1) the court did not err or abuse its discretion when it found the Facebook Messenger records to be authenticated under Me. R. Evid. 901; (2) assuming that the Facebook Messenger statements were hearsay, they were improperly admitted under Me. R. Evid. 803(3), but the error was harmless; and (3) there was sufficient evidence for the jury to find Defendant guilty of murder. View "State v. Tieman" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her two children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a), (B)(2)(a)-(b)(i), (iv), holding that the district court did not commit clear error in terminating Mother's parental rights.Specifically, the Court held (1) the evidence admitted at the termination hearing was sufficient to support the court's unfitness finding; (2) the court's best interest findings did not constitute factual errors or an abuse of discretion because, contrary to Mother's argument, the court's findings were not predicated solely on an assumption that the grandmother would adopt the children; and (3) the procedural interaction between the probate court and the district court did not deprive Mother of due process. View "In re Children of Bethmarie R." on Justia Law

The Supreme Judicial Court affirmed the order of the trial court imposing a discovery sanction following the State's failure to provide Defendant with a dash-cam video of Defendant allegedly committing the crime for which he was charged, holding that a serious sanction was warranted and that the court's choice of sanction was well within its discretion.Defendant was indicted for operating after revocation. Defendant subsequently sent the State a discovery request letter requesting any video or audio that would have been created as part of the stop that led to Defendant's arrest. Although the State had access to the arresting officer's dash-cam video of the stop, the State failed to turn over the video, arguing that it had no "evidentiary value." The trial court ultimately granted Defendant's request to suppress the evidence as a sanction for the State's discovery violation. The Supreme Judicial Court affirmed, holding that the court did not err in finding a discovery violation or abuse its discretion in selecting a sanction that effectively ended the prosecution. View "State v. Reed-Hansen" 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. 22, 4055(1)(b)(2)(a), (b)(i)-(ii), holding that the district court did not err or abuse its discretion by concluding that termination of Father's parental rights was in the best interest of the child.After a hearing, the court found that Father was parentally unfit because he was neither able to protect the child from jeopardy nor able to take responsibility for the child and would be unable to do ether within a time reasonably calculated to meet the child's needs. The court also determined that termination was in the child's best interest. Father appealed, challenging only the court's best interest determination. The Supreme Judicial Court affirmed, holding that the district court did not abuse its discretion by determining that termination Father's parental rights was necessary so that the child could be placed in a stable and permanent setting. View "In re Child of Peter T." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her two children, holding that the district court did not err its findings of unfitness and its best interest determination.The Department of Health and Human Services petitioned for the termination of Mother's parental rights to both of her children. The court subsequently terminated Mother's rights to the children. The Supreme Judicial Court affirmed, holding (1) the court's factual findings of unfitness and best interest were not clearly erroneous; and (2) the court's ultimate determination of best interest was not an abuse of discretion. View "In re Children of Christine A." on Justia Law

The Supreme Judicial Court affirmed the judgments of the probate court determining that the total expenditures made by, and deductions allowable to, Judith Gilbert, as the wife of John Gilbert and personal representative of John's estate, exceeded the value of the estate, and distributing the estate to Judith in kind, holding that the court did not err in its application of the law or in its important factual findings.On appeal, Nathan Gilbert, John's son, put forth fifty-one proposed findings of fact and seventeen proposed corrections of law regarding the value and distribution of the estate, arguing that the court made numerous errors in its findings of fact and its application of the law. The Supreme Judicial Court affirmed the judgments, holding that the probate court acted within its authority and with record support when it found Judith to be credible and did not err when it determined that Judith was entitled to the in kind distribution of the estate. View "In re Estate of Gilbert" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court in favor of the Town of Denmark on Plaintiff's claim that the Town violated Maine's Whistleblowers' Protection Act (WPA), Me. Rev. Stat. 26, 831-40, by suspending Plaintiff after he engaged in what he alleged was WPA-protected activity, holding that the Town's actions were not unlawful.The trial court granted the Town's motion for summary judgment, concluding that Plaintiff had not engaged in WPA-protected activity, a necessary element to succeed in a WPA claim. The Supreme Judicial Court affirmed, holding (1) a dispute over the interpretation of an employment contract, without more, does not constitute a report of illegal activity; and (2) even if Plaintiff subjectively believed that the Town's action violated Maine law or the Town's charter, his subject belief alone was insufficient to meet the WPA's "reasonable cause" requirement. View "Lee v. Town of Denmark" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court entering a protection from harassment order against Appellant, holding that the facts as found by the court were sufficient to prove that Appellant's actions constituted criminal mischief, which constitutes an act of harassment.In entering the order of protection from harassment against Appellant for one year the district court found that Appellant had committed three or more acts of harassment pursuant to Me. Rev. Stat. 5, 4651(2)(A). The Supreme Judicial Court affirmed, holding (1) the court erred in finding because there were three or more acts of harassment; but (2) the court's findings were sufficient to establish the elements of criminal mischief, which can stand alone as a single act of harassment. View "Allen v. Rae" 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), holding that the evidence was sufficient to support the district court's determination of parental unfitness and that termination of Mother's parental rights was in the best interest of the child.Based on the testimony presented at the termination hearing and other evidence the court found, by clear and convincing evidence, that Mother was unwilling or unable to protect the child from jeopardy or to take responsibility for child within a time reasonably calculated to meet the child's needs, and that termination of Mother's parental rights was in the best interest of the child. The Supreme Judicial Court affirmed, holding that there was competent evidence in the record to support the court's findings. View "In re Child of Megan D." on Justia Law