Justia Maine Supreme Court Opinion Summaries

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

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