Justia Maine Supreme Court Opinion Summaries

Townsend Thorndike was convicted of unlawful sexual contact and visual sexual aggression against a child. The charges stemmed from alleged sexual abuse that occurred in the summer of 2021 when the victim was six years old. The State sought to admit a video recording of the victim’s forensic interview under a statutory hearsay exception. Thorndike argued that the statute allowing the video’s admission was unconstitutionally enacted as emergency legislation and violated the separation of powers clause in the Maine Constitution.The trial court initially granted the State’s motion to admit the video but later vacated its order, concluding the statute did not apply retroactively to pending cases. The State then sought and obtained an emergency legislative amendment clarifying the statute’s retroactive applicability. The trial court reinstated its original order, allowing the video’s admission. Thorndike was subsequently convicted on all counts, and the court sentenced him to fourteen years of imprisonment with all but eight years suspended, plus six years of probation.The Maine Supreme Judicial Court reviewed the case and upheld the trial court’s decision. The Court found that the emergency enactment of the statutory amendment was constitutionally valid, as the preamble expressed sufficient facts to constitute an emergency. The Court also determined that the legislative action did not violate the separation of powers doctrine, as it did not mandate the admission of evidence but clarified the statute’s applicability to pending cases. The Court affirmed Thorndike’s conviction and the trial court’s admission of the forensic interview video. View "State of Maine v. Thorndike" on Justia Law

Josh Rinaldi, an inmate at the Maine Correctional Center, slipped on an untreated patch of ice on a paved road within the correctional center, referred to as the "Runway," and broke his ankle. Rinaldi filed a twelve-count complaint asserting various tort claims, arguing that the State was not immune under the Maine Tort Claims Act (MTCA) due to an exception for injuries sustained in or on an appurtenance to a public building.The Superior Court (Androscoggin County) granted Rinaldi's motion for partial summary judgment, ruling that the Maine Correctional Center is a public building under the MTCA and that the Runway is an appurtenance to the correctional center's buildings. The State appealed, arguing that it was immune from liability under the MTCA and that the Runway did not fall under any exceptions to the MTCA.The Maine Supreme Judicial Court reviewed the case and concluded that the Runway is not an appurtenance to the correctional center's buildings. The court applied a three-element test to determine whether the Runway was an appurtenance: physical annexation to the realty, adaptation to the realty, and intent to be irremovable from the realty. The court found that the Runway was not physically annexed to the buildings, was not specially adapted to the buildings, and was not intended to be irremovable from the realty. Therefore, the Runway did not meet the criteria for an appurtenance under the MTCA.The Maine Supreme Judicial Court vacated the Superior Court's judgment granting Rinaldi's motion for partial summary judgment and remanded the case for entry of summary judgment in favor of the State, concluding that the State was immune from liability under the MTCA. View "Rinaldi v. Maine Correctional Center" on Justia Law

Sharon Andersen filed a complaint against the Department of Health and Human Services (DHHS) alleging hostile-work-environment disability discrimination under the Maine Human Rights Act (MHRA). Andersen, who worked for DHHS from 2005 to 2019, claimed that from July 2018 to August 2019, she experienced increased stress and anxiety due to her workload and interactions with her supervisor. She reported panic attacks and was eventually diagnosed with post-traumatic stress disorder (PTSD). Andersen requested reasonable accommodations, including reassignment, which were denied. She went on medical leave in January 2019 and resigned in August 2019, claiming constructive discharge.The Superior Court (Cumberland County) granted summary judgment in favor of DHHS, concluding that Andersen’s claim was time-barred. The court found that the only actions within the statutory limitations period were DHHS’s refusal to reassign Andersen and her resignation, neither of which were discriminatory in themselves or indicative of a continuing violation.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court’s decision. The Court held that Andersen did not make a prima facie showing of a continuing violation. The Court determined that Andersen’s resignation, occurring more than seven months after she went on medical leave, was too disconnected from the alleged hostile work environment to qualify as a constructive discharge. Additionally, the Court noted that DHHS’s refusal to reassign Andersen was not a required reasonable accommodation under the Americans with Disabilities Act (ADA) and the MHRA. Therefore, Andersen’s claim was deemed untimely, and the summary judgment in favor of DHHS was affirmed. View "Andersen v. Department of Health and Human Services" on Justia Law

Monika McCallion, Brandan McCallion, and Old Bears, LLC (collectively, the McCallions) appealed a judgment affirming the Bar Harbor Board of Appeals' decision to uphold the issuance of a 2023 short-term rental registration to W.A.R.M. Management, LLC. The Town of Bar Harbor requires annual registration of short-term rental properties, classifying them as either VR-1 or VR-2. W.A.R.M. Management, LLC owns two VR-2 properties, one of which is central to this dispute. The property in question is in a district where VR-2s are generally prohibited unless they were registered before December 2, 2021. W.A.R.M. submitted renewal applications and fees for both properties in January 2023, but due to a malfunction in the Town's online portal, one application was lost, and the registration was not renewed by the May 31 deadline. The Town's code enforcement officer (CEO) later issued a registration for the property in October 2023 after determining that W.A.R.M. had timely submitted its renewal application.The McCallions filed an administrative appeal with the Bar Harbor Board of Appeals, arguing that the CEO could not renew the registration after the deadline. The Board upheld the CEO's actions after a de novo hearing. The McCallions then filed a Rule 80B complaint in the Superior Court, which affirmed the Board's decision without addressing the Town's mootness argument. While the case was pending, W.A.R.M. received a 2024 registration for the property, which the McCallions did not contest.The Maine Supreme Judicial Court reviewed the case and determined that the appeal was moot because the 2023 registration had been superseded by the 2024 registration, which was not appealed. The court concluded that even if it ruled in favor of the McCallions regarding the 2023 registration, it would have no practical effect since the 2024 registration was final and not subject to review. The court dismissed the appeal as moot, noting that no exceptions to the mootness doctrine applied in this case. View "McCallion v. Town of Bar Harbor" on Justia Law

Damion L. Butterfield was convicted of murder and other offenses after pleading guilty following a trial but before the jury announced its verdict. He sought to withdraw his guilty plea, arguing that the court abused its discretion by denying his request and his motion for a new trial. Butterfield also appealed his thirty-five-year prison sentence.The trial court (Cumberland County, MG Kennedy, J.) denied Butterfield's motion to withdraw his plea and his motion for a new trial. The court found that Butterfield had multiple opportunities to discuss his options with counsel and that his plea was made voluntarily and with full knowledge of the consequences. The court also noted that Butterfield did not assert his innocence and that the plea was entered after thorough colloquies. The court sentenced Butterfield to thirty-five years in prison, consistent with the joint recommendation of the parties.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the trial court did not abuse its discretion in denying Butterfield's motion to withdraw his plea, as the plea was made voluntarily and with full understanding of the consequences. The court also dismissed Butterfield's appeal of his sentence, noting that discretionary review is unavailable for sentences imposed pursuant to a joint recommendation of the parties. View "State of Maine v. Butterfield" on Justia Law

Raymond Ellis Jr. was convicted of robbery and possession of a firearm by a prohibited person. On August 5, 2023, Ellis, armed with a handgun, and a juvenile accomplice, armed with a sawed-off shotgun, robbed the Big Apple convenience store in Madison. They wore masks, threatened the store clerk, and stole cash from the registers. A third person acted as a lookout. Ellis was sentenced to twenty-five years for robbery, with all but twenty years suspended, and four years of probation, plus a concurrent three-year term for the firearm possession charge.The jury found Ellis guilty of robbery, criminal threatening with a dangerous weapon, and theft by unauthorized taking. The court found him guilty of possession of a firearm by a prohibited person after Ellis waived his right to a jury trial on that count. The court merged the criminal threatening and theft counts with the robbery count for sentencing purposes. Ellis appealed, arguing entitlement to a missing-witness jury instruction and errors in the sentencing process.The Maine Supreme Judicial Court reviewed the case. Ellis contended that the jury should have been instructed to infer that a missing witness would not have corroborated the State’s theory. The court reaffirmed its stance from State v. Brewer, holding that no such inference is permissible. The court also addressed Ellis’s claim of double-counting sentencing factors, noting that the sentencing court improperly considered Ellis’s failure to take responsibility as an aggravating factor. The court vacated Ellis’s sentence and remanded for resentencing, affirming the judgment of conviction in all other respects. View "State of Maine v. Ellis" on Justia Law

Peter A. Smith visited Mercy Hospital twice in June 2017 with symptoms indicative of Lyme disease. Dr. John R. Henson misdiagnosed him on both occasions, leading to a lack of appropriate treatment. Smith subsequently developed Lyme carditis and died on July 2, 2017. His parents, Angela M. Smith and Richard T. Smith Jr., as co-personal representatives of his estate, filed a medical negligence lawsuit against Henson, Mercy Hospital, and Eastern Maine Healthcare Systems.The Superior Court (Cumberland County) ruled that Maine’s Wrongful Death Act allowed recovery for pecuniary injuries even if the decedent would not have provided financial support to the beneficiaries. A jury found the defendants liable and awarded damages, including $2 million for pecuniary injury to Smith’s parents, despite no evidence that Smith would have financially supported them.The Maine Supreme Judicial Court reviewed the case. The court held that the applicable wrongful death statute authorized recovery for pecuniary injury only when the death deprived one or more of the people identified in the statute of prospective financial gain. The court concluded that damages for such a loss were not available when the loss was asserted only by the estate. Consequently, the court vacated the portion of the judgment awarding damages for pecuniary injury. All other aspects of the judgment were unaffected, and the case was remanded for entry of a modified judgment consistent with the opinion. View "Smith v. Henson" on Justia Law

Katherine Fratello loaned Russell A. Mann $60,000 under a secured promissory note, with Mann agreeing to make monthly payments starting October 15, 2023. Mann provided a cashier’s check for $3,500 on September 29, 2023, claiming it covered the first two payments and other loans. Fratello disputed the validity of the check and considered Mann in default for missing the first two payments. She served Mann with a default notice on November 29, 2023, and filed a complaint on January 5, 2024, alleging Mann’s failure to make the required payments.Mann counterclaimed, asserting that Fratello breached their contract by not cashing the cashier’s check, which he claimed covered the first two payments. He argued that Fratello’s refusal to accept the payment and the subsequent default notice were unlawful. Fratello filed a special motion to dismiss Mann’s counterclaim under Maine’s anti-SLAPP statute, arguing that the counterclaim was based on her protected petitioning activity, namely the default notice and the complaint.The Superior Court (Cumberland County) denied Fratello’s special motion to dismiss, concluding that the default notice was not petitioning activity and that Mann’s counterclaim was not based on Fratello’s filing of the complaint or any other petitioning activity. Fratello appealed the decision.The Maine Supreme Judicial Court reviewed the denial of the anti-SLAPP motion de novo and affirmed the lower court’s decision. The court held that Mann’s counterclaim was based on Fratello’s refusal to accept the cashier’s check, not on her petitioning activity. Therefore, Fratello did not meet her burden to demonstrate that Mann’s counterclaim was based on protected petitioning activity under the anti-SLAPP statute. View "Fratello v. Mann" on Justia Law

Rochelle Gleason was convicted of aggravated trafficking of a scheduled drug that caused the death of a person. In October 2021, Gleason communicated with the decedent about purchasing fentanyl and heroin. On October 16, 2021, the decedent bought drugs from Gleason, consumed them, and died of acute intoxication from fentanyl and kratom. The Maine Office of the Chief Medical Examiner sent a blood sample to a lab, where several employees conducted tests. A forensic toxicologist, Chelsea Deisher, reviewed the data and documentation and developed a toxicology report indicating the presence of fentanyl and kratom in the decedent’s blood.The State charged Gleason on September 28, 2022, and she pleaded not guilty. During the trial, Deisher testified about the test results, although she did not conduct the tests herself. Gleason objected, arguing that her Sixth Amendment right to confront the witnesses against her was violated because she could not cross-examine the actual testers. The trial court allowed Deisher’s testimony, and the jury found Gleason guilty. She was sentenced to eighteen years in prison, with all but eight years suspended, and four years of probation. Gleason appealed the conviction.The Maine Supreme Judicial Court reviewed the case, focusing on the Confrontation Clause issue. The court noted that the U.S. Supreme Court’s decision in Smith v. Arizona, issued during the appeal, rejected the rationale that allowed experts to testify based on out-of-court statements not admitted for their truth. The court found that Deisher’s testimony relied on the truth of the data and documentation generated by others, which Gleason could not cross-examine. The court vacated the judgment and remanded the case for a new trial to determine whether the statements relied upon by Deisher were testimonial. View "State of Maine v. Gleason" on Justia Law

Kathleen M. Barron filed for divorce from John D. Barron in April 2022. The District Court in Bangor held a contested bench trial where both parties testified and submitted evidence, including proposed calculations for the division of assets. The court ordered John to make a $57,790.17 payment to Kathleen to equalize the division of property, or the marital home, which also houses John's business, would be sold.John appealed the decision, arguing that the court did not make sufficient findings to support the equalization payment. He had filed a post-judgment motion for further findings of fact, which the trial court denied. The Maine Supreme Judicial Court noted that the divorce judgment lacked specific findings regarding the valuation and classification of assets, making appellate review impossible. The court highlighted that the trial court must provide express factual findings based on the record to support its decisions.The Maine Supreme Judicial Court vacated the judgment in part and remanded the case for further findings. The court emphasized that the trial court must independently assess the valuation evidence before equitably dividing marital property. The judgment was vacated concerning the distribution of property, while the remainder of the judgment was affirmed. The case was remanded for further proceedings consistent with the opinion, allowing the trial court discretion to reopen the evidence if necessary. View "Barron v. Barron" on Justia Law