Justia Maine Supreme Court Opinion Summaries

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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

Posted in: Family Law
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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

Posted in: Family Law
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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

Posted in: Trusts & Estates
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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

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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

Posted in: Criminal Law
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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

Posted in: Family Law
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The Supreme Judicial Court affirmed the judgment of the superior court in favor of the State on the State's complaint against Defendants for fraudulent transfer pursuant to Me. Rev. Stat. 14, 3575(1)(A), holding that the State's complaint was timely filed and that the court's findings were supported by competent evidence in the record.On appeal, Defendants argued that the State's action was barred by Me. Rev. Stat. 14, 3580(1). Under that statute, a cause of action with respect to a fraudulent transfer is extinguished unless brought within six years after the transfer or, if later, within one year after the transfer was or reasonably could have been discovered. The superior court determined that Defendants were equitably estopped from asserting the bar set out in section 3580(1) as an affirmative defense. The Supreme Judicial Court held (1) section 3580 is a statute of repose that has displaced the common law doctrine of estoppel on which the court relied in rejecting Defendants' section 3580(1) defense; but (2) the court's factual findings applied to trigger the one-year discovery exception to the six-year limitation provided in the statute. View "State v. Tucci" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated the order of the trial court suppressing evidence obtained during a traffic stop, holding that the motion court erred in restricting its legal analysis to certain evidence.The evidence suppressed in this case was obtained after a Maine State Police trooper stopped and ordered Defendant out of the motor vehicle she was driving so that he could administer field sobriety tests to her. The trial court concluded that the vehicle stop was valid but the subsequently investigatory seizure was not. The Supreme Judicial Court vacated the suppression order, holding that the motion court erred in restricting its analysis to evidence of the events and circumstances occurring at and prior to the moment that the trooper realized that the driver was not the person who was the subject to the complaint that led to the traffic stop. The Court then remanded the case for a determination as to whether the trooper's subsequent actions were reasonably related in scope to the purpose of the initial stop. View "State v. Bennett-Roberson" on Justia Law

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The Supreme Judicial Court affirmed in part and vacated in part the judgment of the Business and Consumer Docket entering a declaratory judgment invalidating all rules and regulations previously promulgated by Fall Line Condominium Association's Board of Directors, holding that the declaratory judgment voiding rules and regulations not approved by a majority in interest of unit owners that concern the use of units, common areas, and facilities was proper but that the declaratory judgment as to all other rules and regulations was not.Plaintiffs, who owned a unit at Fall Line, filed a complaint against the Association and certain members of the Board seeking a declaratory judgment that all rules, regulations, and limitations affecting unit owners and their use of their units and any common element at the condominiums not approved by a majority in interest by the unit owners were void. The Business Court granted summary judgment in favor of Plaintiffs. The Supreme Judicial Court held (1) the Association's bylaws unambiguously states that the Board, in order to promulgate or amend rules of conduct concerning the use of the units, common areas, and facilities, must seek approval from a majority in interest of unit owners; and (2) there is no such limitation on other types of rules or regulations governing the general operation and use of the property. View "Scott v. Fall Line Condominium Ass'n" on Justia Law

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The Supreme Judicial Court affirmed the post-judgment orders following a divorce judgment entered in the district court finding Edward Harshman in contempt, holding that the facts of this case supported the contempt order.The district court's orders of contempt found Edward in contempt of the parties' divorce judgment after he failed to obtain a $500,000 life insurance policy that would name Sheila Harshman, his former wife, as the owner and beneficiary, and acted in bad faith allowing his existing life insurance policy that listed Sheila as the beneficiary to lapse. The Supreme Judicial Court affirmed the judgment of contempt, holding that Edward failed to produce evidence of his inability to comply with insurance provision of the divorce judgment. View "Harshman v. Harshman" on Justia Law

Posted in: Family Law