Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of three counts of possession of sexually explicit material of a minor under age twelve, holding that the court did not err in denying Defendant’s motion to suppress evidence seized pursuant to a search warrant.On appeal, Defendant argued that the search warrant was stale, failed to describe the items to be seized with “scrupulous exactitude,” as required by the First Amendment, and otherwise failed to describe the places to be searched and the items to be seized with sufficient particularity. The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress, holding (1) the trial court did not err in ruling that the information the court relied on was not stale; (2) the warrant’s description of the items to be seized and the purpose for their seizure did not implicate the heightened “scrupulous exactitude” standard; and (3) the warrant was not overbroad and satisfied the constitutional requirement for particularity. View "State v. Roy" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Parents’ parental rights to their children pursuant to Me. Rev. Stat. 22, 4050-4056, holding that the record supported the court’s findings that at least one ground of parental unfitness had been proved and that termination of Parents’ rights was in the children’s best interests.On appeal, Father advanced no arguments, but Mother argued that the district court erred in taking judicial notice of prior proceedings. The Supreme Judicial Court disagreed, holding (1) the district court independently assessed all facts presented; and (2) the court’s determination that termination of parental rights was established by clear and convincing evidence was supported by the record. View "In re Children of Bradford W." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to four of her children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii), (iv), holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Court held (1) Mother’s counsel at the termination hearing did not provide ineffective assistance in failing to seek recusal and failing to move for further findings; (2) the district court’s findings were supported by the record; and (3) the district court did not err in making a credibility determination concerning one of Mother’s witnesses. View "In re Children of Crystal G." on Justia Law

In this appeal from a family matter judgment after a judicial review hearing in a child protection matter the Supreme Judicial Court dismissed the appeal from the child protection matter and affirmed the judgment in the family matter, holding that the issue raised in the child protection matter was not properly raised and that there was no error or abuse of discretion in the family matter.The district court dismissed the child protection matter, opened a family matter, and entered an order in the family matter that gave sole parental rights and responsibilities to Mother and denied rights of contact to Father. The Supreme Judicial Court held (1) because the entry of the family matter judgment was appealable only pursuant to Me. Rev. Stat. 19-A, 104, Father improperly raised his issue in a Me. Rev. Stat. 22, 4006, 4038 appeal; (2) when a party appeals from a family matter judgment entered as a result of an unappealable judicial review hearing in a child protection matter, the right to counsel does not extend to the appeal from the family matter judgment; and (3) the court did not err in denying Father’s motion to testify by video link or in denying Father’s request for rights of contact with the child. View "In re Child of Nicholas G." on Justia Law

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 court did not err in determining that Father remained unable to protect the child from jeopardy or take responsibility for the child within a time that is reasonably calculated to meet the child’s needs, and the court id not err or abuse its discretion in determining that termination of Father’s parental rights was in the child’s best interest.Based on testimony presented at the termination hearing and other competent evidence in the record, the district court found by clear and convincing evidence that termination of Father’s parental rights was in the best interest of the child. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion in the proceedings below. View "In re Child of Jonathan D." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment to Defendant, PropertyInfo Corporation, Inc., on York County’s complaint alleging breach of contract and unjust enrichment, holding that the court did not err in its determination that York County’s claims were barred by the statute of limitations.York County’s action was based on PropertyInfo’s failure to digitize and make accessible all documents filed with the York County Registry of Deeds between 1940 and 1965. The superior court entered a summary judgment in favor of PropertyInfo, concluding that the statute of limitations had expired on each of York County’s claims. The Supreme Judicial Court affirmed, holding that the superior court properly entered summary judgment based on the expiration of the statute of limitations on each of the claims. View "York County v. PropertyInfo Corp., Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying Christopher McMahon’s motion for contempt and granting Tanya McMahon’s motion to modify the parties’ divorce judgment and the court’s order denying Christopher’s motion to alter or amend the judgment and granting in part Christopher’s motion for additional findings of fact and conclusions of law, holding that there was no error or abuse of discretion on the part of the district court.Specifically, the Court held that the district court did not err or abuse its discretion by (1) denying Christopher’s motion for contempt; (2) failing to implement a partial mediation agreement; (3) denying a deviation from the child support guidelines; and (4) imposing conditions on Christopher’s visitation rights. View "McMahon v. McMahon" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder and elevated aggravated assault, entered after a bench trial, holding that there was no error in the proceedings below.Specifically, the Court held (1) the evidence was sufficient to support the trial court’s factual findings, as well as its ultimately finding that Defendant was at least an accomplice in the murder and assault; (2) Defendant was not denied the due process guaranteed by the Fourteenth Amendment during trial; (3) the trial court did not err in allowing two witnesses to identify Defendant in court; and (4) the court did not err or abuse its discretion in certain evidentiary rulings challenged by Defendant on appeal. View "State v. Ferguson" on Justia Law

The Supreme Judicial Court vacated the summary judgment entered by the superior court in favor of Defendant on Plaintiff’s complaint asserting that Defendant was negligent and had caused Plaintiff economic harm, holding that claim preclusion cannot operate to bar a subsequent suit brought in district or superior court by a person who was not an actual party in a previous small claims action.A third party driving a vehicle owned by Plaintiff was involved in a collision with a vehicle driven by Defendant. In a small claims matter, Defendant sued the third party, and the district court found the third party was negligent. Plaintiff then brought this action against Defendant. The superior court applied the doctrine of res judicata to the earlier small claims judgment and determined that the earlier judgment conclusively resolved the issue of which driver was at fault. The Supreme Court vacated the judgment, holding that, because of the unique limitations of small claims procedure, claim preclusion did not bar this suit by a person who was, at most, in privity with the defendant in the small claims case. View "Ring v. Leighton" on Justia Law

The Supreme Judicial Court vacated the order to enforce payment of restitution entered by the superior court following a hearing on a motion to enforce payment of a restitution obligation originally imposed as part of a sentence, holding that the motion court erred in imposing the burden on Defendant to prove the current balance of the court-ordered restitution for the victim’s uncompensated losses.Specifically, the Supreme Judicial Court held that the State never met the burden assigned to it in State v. Nelson, 994 A.2d 808 (Me. 2010), and State v. Berube, 698 A.2d 509 (Me. 1997), to determine the amount of the victim’s loss, payments credited to cover that loss, an thus the remaining sum that Defendant should have been obligated to pay in restitution. Because the State did not meet its burden to establish the amount still owed when it filed its motion to enforce the restitution obligation, the Supreme Judicial Court remanded for a new hearing on the enforcement of the restitution obligation with the State having the burden to prove the restitution obligation remaining. View "State v. Gagne" on Justia Law