Justia Maine Supreme Court Opinion Summaries

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

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

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

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

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

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