Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Mother and Father to their child, holding that the court did not clearly err in finding both parents unfit and did not abuse its discretion in concluding that termination of the parents' rights was in the best interest of the child.Specifically, the Court held (1) the court did not Cleary err in finding, by clear and convincing evidence, that Father was unable or unwilling to protect the child from jeopardy or take responsibility for the child within a time reasonably calculated to meet the child's needs; and (2) even if placing the child in an adoptive home may be challenging, the court did not abuse its discretion in concluding that termination of both parents' rights was in the best interest of the child. View "In re Child of Carl D." 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. 4055(1)(B)(2)(a) and (b)(i)-(ii), holding that the district court's judgment was not an abuse of discretion.Specifically, the Court held (1) the evidence was sufficient to support the court's findings of parental unfitness; (2) the evidence was sufficient to support the court's determination that termination of Mother's parental rights was in the child's best interest; (3) the court did not commit clear error or abuse its discretion in determining that termination was in the child's best interest; and (4) the court did not abuse its discretion when it denied Mother's motions for a new trial or to reopen the evidence. View "In re Child of Erica H." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child, holding (1) the evidence was sufficient to support the court's finding that termination was in the child's best interest, and (2) the court did not abuse its discretion in terminating Mother's parental rights instead of ordering a permanency guardianship.Specifically, the Court held (1) Mother's due process rights were not violated when the court commenced the termination hearing , as scheduled, in Mother's absence; (2) the court did not abuse its discretion in ordering a permanency guardianship rather than a termination of Mother's parental rights; and (3) the evidence was sufficient to support the court's findings. View "In re Children of Danielle F." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his two children, holding that competent record evidence supported the court's determinations and that the court did not err by terminating Father's parental rights.After a termination hearing, the district court determined that Father was parentally unfit and that termination of Father's parental rights was in the children's best interests. The Supreme Court affirmed, holding that the court's determinations were predicated on supported factual findings and the application of the requisite standard of proof, that Father was parentally unfit, and that termination of Father's parental rights was in the best interests of the children. View "In re Children of Anthony N." 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 record supported the court's findings and that the court did not abuse its discretion in concluding that termination of Mother's parental rights was in the children's best interests.Following a hearing, the district court terminated Mother's parental rights based on its finding, by clear and convincing evidence, that Mother was unable to protect the children from jeopardy or take responsibility for the children within a time reasonably calculated to meet their needs, that Mother failed to make a good faith effort at reunification, and that termination of Mother's parental rights was in the children's best interests. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion in the district court's judgment. View "In re Children of Melissa S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights to his children, holding that the court did not err or abuse its discretion by finding that Father was unfit and that termination of Father's parental rights was in the best interests of the children.Specifically, the Court held (1) the court's findings were supported by competent evidence in the record; (2) the court did not err in determining that Father was unable or unwilling to protect the children from jeopardy within a time reasonably calculated to meet the children's needs; and (3) the court did not abuse its discretion in determining that termination of Father's parental rights was in the best interests of the children. View "In re Children of Anthony L." on Justia Law

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