Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant’s conviction of operating under the influence (OUI) with a refusal to submit to a chemical test, holding that the jury instructions given in this case were not confusing to the jury.Here, the State presented two alternative theories of guilt - principal liability and accomplice liability. On appeal, Defendant argued that the trial court abused its discretion when it denied his motion for a new trial because the jury instructions on a driver’s duty to submit to a chemical test and on accomplice liability confused the jury and did not provide a roadmap for the jury to be able to return a not guilty verdict. The Supreme Judicial Court affirmed after clarifying and distinguishing the two alternate theories, holding (1) the jury instructions were clear that the refusal instruction was inapplicable to the charge of accomplice liability in an OUI case; and (2) there was no prejudice to Defendant that resulted in an unfair trial. View "State v. Perkins" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court divorcing Husband and Wife, holding that the court did not err by adopting Wife’s proposed judgment and did not err in its classification of marital property and the determination of Husband’s income.Specifically, the Court held (1) the district court’s order clearly reflected its independent judgment and was fully supported by competent evidence in the record; (2) the court’s allocation of the parties’ marital assets was without error; and (3) the trial court’s determination of Husband’s income was supported by sufficient, competent record evidence. View "Cashman v. Robertson" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s and Father’s parental rights to two of their children, holding, among other things, that the evidence was sufficient to support the court’s determination that Mother was parentally unfit within the meaning of Me. Rev. Stat. 22, 4055(1)(B)(2)(b)(ii)-(iv).Specifically, the Court held (1) even if the evidence shows that the Department did not fulfill its statutory duty to develop a proper rehabilitation and reunification plan, such a failure is not dispositive of a termination petition; (2) the district court’s determination of Father’s parental unfitness with regard to his two children was supported by competent evidence in the record; and (3) the court’s determination of Mother’s parental unfitness was supported by competent record evidence. View "In re Children of Corey W." on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court granting summary judgment in favor of Littlebrook Airpark Condominium Association on the Association’s action for a declaratory judgment on the issue of the effectiveness of a lease amendment, holding that the amendment was void.The superior court found that, although the lease amendment resulted in a default of the mortgage encumbering property owned by Sweet Peas, LLC, the lease amendment was still effective. On appeal, Sweet Peas and party-in-interest Jean Hardy argued that the amendment was void because any rights created by the amendment were subordinate to the existing mortgage on the property and were therefore extinguished by Hardy’s foreclosure. The Supreme Judicial Court agreed, holding that the lease amendment was invalid because it was a new interest created after the mortgage, rendering the amendment junior to the mortgage. View "Littlebrook Airpark Condominium Ass’n v. Sweet Peas, LLC" on Justia Law

The Supreme Judicial Court affirmed the order of the district court denying the Passamaquoddy Tribe’s motion to intervene in a child protective action involving nonmember children following the removal of the children from the custody of their mother, who resided in the Tribe’s territory, holding that the district court did not err in determining that the Department of Health and Human Services’ removal of the children from the Tribe’s territory was not impermissible state regulation of an “internal tribal matter.”Following the Department’s removal of the children from their mother’s care, the Tribe filed a motion to intervene, alleging that Me. R. Civ. P. 24(a)(2) provided for intervention of right because the removal of the children from the Tribe’s territory constituted impermissible state regulation of an internal tribal matter. The court denied the motion to intervene. The Supreme Judicial Court affirmed, holding (1) the removal of the children did not constitute impermissible state regulation of an internal tribal matter; and (2) the district court did not abuse its discretion by denying the Tribe’s motion for permissive intervention. View "In re Children of Mary J." on Justia Law

The Supreme Judicial Court affirmed the order of the district court denying Appellants’ and the Oglala Sioux Tribe’s motions to transfer jurisdiction of this child protection matter to the Oglala Sioux Tribal Court pursuant to the Indian Child Welfare Act (ICWA), 25 U.S.C. 1901-1963, holding that the district court properly found that there was good cause within the meaning of ICWA not to transfer the matter to the Tribal Court.There was no dispute in this case that these were child custody proceedings to which ICWA applied, the children were Indian children within the meaning of ICWA, and the children did not reside on the reservation in South Dakota. Here, the district court focused on the difficulty in the presentation of evidence that would occur if jurisdiction were transferred from Maine to South Dakota. The Supreme Judicial Court affirmed, holding that the court’s denial of the motion to transfer was supported by its findings and conclusions and that the court’s analysis of the geographical challenges posed by a potential transfer was supported by ample evidence, contained no legal errors, and did not represent an abuse of discretion. View "In re Children of Shirley T." on Justia Law