Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Plaintiff’s defamation action against Defendant, his former supervisor, for failure to state a claim under Me. R. Civ. P. 12(b)(6), holding that the superior court did not err in determining that Defendant was immune from liability pursuant to the Maine Tort Claims Act, Me. Rev. Stat. 14, 8111(1)(C).When Plaintiff’s began working as an assistant attorney general in the Maine Attorney General’s office, Defendant was Defendant’s direct supervisor. After Plaintiff was terminated, he commenced this action asserting claims against Defendant for libel per se and slander per se. The superior court granted Defendant’s motion to dismiss, determining that Plaintiff’s claims were barred by the discretionary function immunity provision of the Maine Tort Claims Act. The Supreme Judicial Court affirmed, holding (1) Defendant’s statements were not actionable because of discretionary function immunity; and (2) Plaintiff’s complaint failed to allege facts sufficient to overcome a motion to dismiss. View "Lawson v. Willis" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence and operating beyond a license condition or restriction, holding that the trial court did not err by excluding testimony of two witnesses that Defendant had designated as experts.Defendant designated the two experts to testify that, at the time of his arrest, he had a condition known as “auto-brewery syndrome,” a phenomenon associated with the production of alcohol within the body itself under certain circumstances. The Supreme Court affirmed the trial court’s judgment, holding (1) the record supported the trial court’s findings that Defendant’s first witness was not sufficiently qualified to testify generally about auto-brewery syndrome and did not have a sufficient basis to opine that Defendant had that condition at the time of his arrest; and (2) the trial court properly excluded testimony of Defendant’s second proposed expert witness because of Defendant’s significant delay in designating her. View "State v. Burbank" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder and elevated aggravated assault with a firearm, holding that there was sufficient evidence to support the convictions and that the trial court did not err in its instructions to the jury.On appeal, Defendant argued that the trial court erred by (1) denying his requested jury instruction on eyewitness identification and by giving an inadequate instruction on eyewitness identification, and (2) overemphasizing the definition of accomplice liability in instructing the jury. The Supreme Judicial Court disagreed, holding (1) the trial court did not err in denying Defendant’s proposed jury instruction; (2) the trial court did not err in its instruction on accomplice liability; and (3) there was sufficient evidence to support Defendant’s conviction for murder and elevated aggravated assault. View "State v. Hansley" 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 there was sufficient evidence to support the court’s findings of parental unfitness.Based on its findings, the lower court found grounds to terminate Mother’s parental rights to her children pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(b)(i), (ii) and (iv). The court further determined that termination of Mother’s parental rights was in the children’s best interests. On appeal, Mother challenged the sufficiency of the evidence supporting all three grounds of parental unfitness. The Supreme Judicial Court held that the record contained sufficient evidence to support the court’s findings as to all three grounds of parental unfitness. View "In re Children of Tiyonie R." on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the superior court after a jury verdict finding Defendant guilty of unlawful sexual contact and assault, holding that the superior court did not err in admitting part of a report of a sexual assault forensic examination (SAFE) performed on the adult female victim upon her arrival at Maine General Hospital.On appeal, Defendant challenged the admission of the report, arguing that the admitted portion did not satisfy the requirements of Me. R. Evid. 803(4). Defendant also argued that, even if the report were admissible, it was cumulative or unduly prejudicial and should have been excluded pursuant to Me. R. Evid. 403. The Supreme Judicial Court affirmed, holding (1) a SAFE report may be admitted over a hearsay objection if it also meets all other evidentiary rules and complies with the requirements of Me. Rev. Stat. 16, 357; (2) the superior court did not err in determining that the State had satisfied the requirements set forth in section 357; and (3) the court did not err in concluding that the probative value of the report was not outweighed by the danger of unfair prejudice. View "State v. Jones" on Justia Law

The Supreme Judicial Court vacated the judgment of divorce entered by the district court on Donald Durkin’s complaint and the court’s denial of Joyce Durkin’s motion for amended or clarified findings and for reconsideration, holding that the court’s judgment was unclear.At issue was whether district court erred by concluding that it lacked the authority to award spousal support from nonmarital assets and by declining to award nominal spousal support. The Supreme Judicial Court held (1) the district court did have the authority to consider a spouse’s nonmarital assets in determining the appropriateness of spousal support; (2) the district court did have the authority to secure any spousal support through a lien on nonmarital property; but (3) the district court’s judgment was unclear as to whether the court believed it had such authority. The Supreme Judicial Court remanded for clarification of the court’s analysis and conclusions and for reconsideration as deemed necessary, holding that from the court’s language in its order, the court apparently erred in its legal analysis regarding its ability to consider nonmarital property in determining whether to award spousal support - and in its ability to fashion a remedy to enforce any such award. View "Durkin v. Durkin" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to two of his children pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i)-(ii),(iv), holding that the district court did not err or abuse its discretion in determining that the termination of Father’s parental rights was in the children’s best interests.Specifically, the Court held (1) the evidence provided the district court with ample support for the court’s conclusion that termination of Father’s parental rights was in the children’s best interests; and (2) the district court’s determination that the circumstances of this case warranted termination of Father’s parental rights while preserving Mother’s parental rights was not erroneous. View "In re Children of Christopher S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Appellant’s motion for a new trial brought pursuant to Maine’s post-conviction DNA analysis statute, 15 Me. Rev. Stat. 2136-2138, holding that, under the circumstances, the superior court did not err in denying Appellant’s motion for a new trial.Appellant was convicted of two counts of murder. Appellant later filed a motion for a new trial based on mitochondrial DNA testing performed at his request. The superior court denied Appellant’s request for a new trial following an evidentiary hearing. The Supreme Judicial Court affirmed, holding that the superior court did not err in its determination that Appellant failed to prove by clear and convincing evidence that the evidence found on the victim and tested pursuant to Appellant’s DNA testing request could only have come from the perpetrator of the crime. View "State v. Cookson" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing for lack of subject matter jurisdiction Plaintiffs’ Me. R. Civ. P. 80B complaint for review of factual findings made by the Board of Appeals of the Town of York, holding that the superior court had jurisdiction to review the Board’s decision.Plaintiffs contacted the Town’s Code Enforcement Officer (CEO) to express their concern that their neighbor’s use of his property was not consistent with the previous owner’s nonconforming use. The CEO found no violations. The Board found that the neighbor’s use of the lot did not constitute a change in use but was rather an intensification of the previous use. Plaintiffs appealed to the superior court pursuant to Rule 80B. The court granted the Town’s motion to dismiss, concluding that the Board’s review of the CEO’s decision was advisory and, therefore, unreviewable. The Supreme Judicial Court affirmed, holding that, absent an express provision in the Town’s ordinance stating that Plaintiffs may not appeal, a determination of whether there has been a violation of the ordinance is reviewable on appeal. View "Raposa v. Town of York" on Justia Law

The Supreme Judicial Court vacated the judgment of the the district court granting summary judgment in favor of MaineStream Finance on Jacob Berry’s complaint seeking the return of a 2016 Chevrolet Camaro, holding that summary judgment was improper on the facts of this case.In 2016, MaineStream filed an action against Dwight Moody, Berry’s uncle, to repossess two race cars - including the car called “Outlaw" - that Moody had pledged as collateral in a security agreement. The court found that Moody was the owner of Outlaw and entered a final judgment. In 2017, Berry brought this action against MaineStream, alleging that MaineStream wrongfully seized his 2016 Chevrolet Camaro. The district court granted MaineStream’s motion for summary judgment based on MaineStream’s assertion that, in the 2016 action, the court determined that Moody owned the car and that Berry was barred from seeking relief pursuant to the doctrine of res judicata. The Supreme Judicial Court vacated the judgment, holding that summary judgment was improper because the record did not establish that Outlaw was the same vehicle was the one that was at issue in the instant case. View "Berry v. Mainstream Finance" on Justia Law