Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the superior court denying in part and granting in part Appellant's petition for post-conviction relief as to his felony convictions, holding that the court erred by denying Appellant's petition despite its determination that Appellant had proved ineffective assistance of counsel for Appellant's misdemeanor charge.Appellant was convicted of both felony and misdemeanor counts. Appellant later filed a petition for post-conviction review, alleging ineffective assistance of counsel. The superior court found that Appellant had been denied his right to effective assistance of counsel by counsel's refusal to discuss Appellant's right to testify but concluded that trial counsel's actions prejudiced Appellant only with regard to Appellant's conviction for misdemeanor theft by unauthorized taking. The Supreme Judicial Court vacated the court's judgment and remanded the case, holding that, as a result of counsel's deficient performance, Appellant was prejudiced in his attempt to defend all charges brought against him, entitling him to post-conviction relief from his convictions on all counts. View "Ford v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs, holding that the court did not err during the proceedings below.On appeal, Defendant challenged the trial court's use of the term "aggravated" in informing the jury of each charge at the beginning of trial and challenged the manner of the court's polling of the jurors. The Supreme Judicial Court affirmed, holding (1) the court's use of the term "aggravated" in one sentence in its introductory remarks to the jury did not constitute obvious error affecting Defendant's substantial rights; and (2) the court did not commit obvious error in its timing of the jury polling. View "State v. Robinson" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment in favor of Property Owners in this property dispute, holding that rockweed, a species of seaweed that grows in Maine's intertidal zone, is private property that belongings to the adjoining upland landowner who owns the intertidal soil in fee simple and is therefore not public property.Acadian Seaplants, Ltd. harvested rockweed attached to intertidal land without permission of Property Owners, owners of upland property where the rockweed grew. Property Owners commenced this action against Acadian seeking a declaratory judgment and injunctive relief. The superior court entered judgment in favor of Property Owners. The Supreme Judicial Court affirmed, holding that rockweed in the intertidal zone belongs to the upland property owner and is therefore not held in trust by the State for public use and cannot be harvested by members of the public as a matter of right. View "Ross v. Acadian Seaplants, Ltd." on Justia Law

The Supreme Judicial Court affirmed Defendant's drug-related convictions, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained as the result of a roadside interaction with a police officer and that any potential challenge to the sentence imposed was not cognizable on direct appeal.Defendant was convicted of unlawful possession of scheduled drugs, unlawful possession of scheduled drugs, and refusing to submit to arrest or detention. On appeal, Defendant argued that his roadside encounter with the officer rose to the level of a detention and was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding (1) the trial court correctly found that the officer's conduct and interaction with Defendant did not rise to the level of a Fourth Amendment seizure; and (2) Defendant's challenge to his sentence was not cognizable on this direct appeal. View "State v. Cunneen" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of domestic violence assault, holding that the trial court did not err in admitting into evidence a recording of a 911 call by the alleged victim of the domestic violence assault for emergency assistance even where the victim did not testify at trial.The trial court concluded that the victim's recorded statements fell within the excited utterance exception to the hearsay rule and that the statements were nontestimonial. The Supreme Judicial Court affirmed, holding that the trial court did not err in determining that the victim's statements on the recording were both excited utterances and nontestimonial and thus not subject to exclusion by the Confrontation Clause. View "State v. Sykes" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court in favor of Matthew Needham on a foreclosure complaint filed by Wilmington Savings Fund Society as Trustee for Hilldale Trust (Wilmington) and remanded the matter for entry of judgment for Wilmington, holding a mortgagee may delegate to an agent its duty to provide a notice of the right to cure pursuant to Me. Rev. Stat. 14, 6111(1).After Needham defaulted on his loan, loan servicer BSI Financial Services sent Needham a notice of the right to cure on behalf of Ventures Trust, the then-holder of the note and mortgage. Thereafter, Ventures Trust filed a foreclosure complaint. Wilmington, which was assigned the mortgage and note, was subsequently substituted as Plaintiff. The trial court entered judgment for Needham, concluding that because the notice was sent by the loan servicer rather than the mortgagee, the notice was insufficient to satisfy the requirements of section 6111. The Supreme Judicial Court disagreed, holding that neither the mortgage contract nor Me. Rev. Stat. 6111(1) prohibited the mortgagee from delegating to an agent loan servicer its duty to give a notice of the right to cure to Needham. View "Wilmington Savings Fund Society, FSB v. Needham" on Justia Law

The Supreme Judicial Court vacated the aggravating factors that elevated Defendants’ crime from Class B trafficking in schedule drugs to Class A aggravated trafficking in schedule W drugs, holding that there was insufficient evidence to convict Defendant of all four counts.The State charged Defendant with four counts of Class A aggravated trafficking in schedule W drugs. The jury returned a guilty verdict on all four counts. On appeal, Defendant challenged the sufficiency of the evidence supporting his conviction. The Supreme Judicial Court vacated the aggravating elements of Defendant’s convictions and remanded for resentencing on four counts of trafficking in schedule W drugs, holding (1) Me. Rev. Stat. 17-A, 1105-A(1)(E) requires proof beyond a reasonable doubt that the locus of the drug trafficker at the time of the offense be within 1,000 feet of the real property of a school, measured in a straight line and accounting for any difference in elevation between the two points; and (2) there was insufficient evidence that Defendant trafficked within 1,000 feet of a school. View "State v. Brown" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying Susan McGarvey’s motion to modify a divorce judgment between her and John McGarvey and Susan’s motion to reconsider that denial, holding that there was no error in the court’s judgment.On appeal, Susan argued that the district court erred by determining that there were no substantial changes in circumstances sufficient to justify a modification of the divorce judgment. The Supreme Judicial Court disagreed, holding (1) because Susan failed to provide the Court a transcript of the hearing on her motion to modify, it must be assumed that the court’s findings were supported by competent evidence in the record; and (2) based on those findings, the court did not err in denying Susan’s motion to modify. View "McGarvey v. McGarvey" 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 court did not err in finding that Mother was unfit to parent and that it was in the best interest of the child to terminate Mother’s parental rights.Specifically, the Court held (1) all of the district court’s factual findings had evidentiary support; (2) the district court did not err in determining that, despite Mother’s efforts, she was unable to protect her child from jeopardy or take responsibility for the child within a time that was reasonably calculated to meet the child’s needs; and (3) the court did not err in concluding that the termination of mother’s parental rights was in the child’s best interest. View "In re Child of Amanda H." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in favor of Plaintiff on his claim for medical malpractice against Timothy Pruchnic, M.D. and Eastern Maine Medical Center (collectively, Defendants), holding that the jury did not award excessive damages and that the trial court committed no error in the proceedings below.Specifically, the Court held (1) contrary to Defendants’ contentions, there was competent evidence in the record to support the trial court’s determination that there was a rational relationship between the evidence presented and the jury’s damage award; (2) the trial court did not err in giving a jury instruction pursuant to Lovely v. Allstate Insurance Co., 658 A.2d 1091 (Me. 1995); (3) the trial court acted correctly in redacting several radiology reports; and (4) the trial court did not err by instructing the jury to disregard all references to workers’ compensation after allowing some references to workers’ compensation to be made throughout the trial. View "Nason v. Pruchnic" on Justia Law