Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of conviction entered by the superior court after a jury verdict finding Defendant guilty of unlawful sexual contact and assault, holding that the superior court did not err in admitting part of a report of a sexual assault forensic examination (SAFE) performed on the adult female victim upon her arrival at Maine General Hospital.On appeal, Defendant challenged the admission of the report, arguing that the admitted portion did not satisfy the requirements of Me. R. Evid. 803(4). Defendant also argued that, even if the report were admissible, it was cumulative or unduly prejudicial and should have been excluded pursuant to Me. R. Evid. 403. The Supreme Judicial Court affirmed, holding (1) a SAFE report may be admitted over a hearsay objection if it also meets all other evidentiary rules and complies with the requirements of Me. Rev. Stat. 16, 357; (2) the superior court did not err in determining that the State had satisfied the requirements set forth in section 357; and (3) the court did not err in concluding that the probative value of the report was not outweighed by the danger of unfair prejudice. View "State v. Jones" on Justia Law

The Supreme Judicial Court vacated the judgment of divorce entered by the district court on Donald Durkin’s complaint and the court’s denial of Joyce Durkin’s motion for amended or clarified findings and for reconsideration, holding that the court’s judgment was unclear.At issue was whether district court erred by concluding that it lacked the authority to award spousal support from nonmarital assets and by declining to award nominal spousal support. The Supreme Judicial Court held (1) the district court did have the authority to consider a spouse’s nonmarital assets in determining the appropriateness of spousal support; (2) the district court did have the authority to secure any spousal support through a lien on nonmarital property; but (3) the district court’s judgment was unclear as to whether the court believed it had such authority. The Supreme Judicial Court remanded for clarification of the court’s analysis and conclusions and for reconsideration as deemed necessary, holding that from the court’s language in its order, the court apparently erred in its legal analysis regarding its ability to consider nonmarital property in determining whether to award spousal support - and in its ability to fashion a remedy to enforce any such award. View "Durkin v. Durkin" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to two of his children pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i)-(ii),(iv), holding that the district court did not err or abuse its discretion in determining that the termination of Father’s parental rights was in the children’s best interests.Specifically, the Court held (1) the evidence provided the district court with ample support for the court’s conclusion that termination of Father’s parental rights was in the children’s best interests; and (2) the district court’s determination that the circumstances of this case warranted termination of Father’s parental rights while preserving Mother’s parental rights was not erroneous. View "In re Children of Christopher S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Appellant’s motion for a new trial brought pursuant to Maine’s post-conviction DNA analysis statute, 15 Me. Rev. Stat. 2136-2138, holding that, under the circumstances, the superior court did not err in denying Appellant’s motion for a new trial.Appellant was convicted of two counts of murder. Appellant later filed a motion for a new trial based on mitochondrial DNA testing performed at his request. The superior court denied Appellant’s request for a new trial following an evidentiary hearing. The Supreme Judicial Court affirmed, holding that the superior court did not err in its determination that Appellant failed to prove by clear and convincing evidence that the evidence found on the victim and tested pursuant to Appellant’s DNA testing request could only have come from the perpetrator of the crime. View "State v. Cookson" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing for lack of subject matter jurisdiction Plaintiffs’ Me. R. Civ. P. 80B complaint for review of factual findings made by the Board of Appeals of the Town of York, holding that the superior court had jurisdiction to review the Board’s decision.Plaintiffs contacted the Town’s Code Enforcement Officer (CEO) to express their concern that their neighbor’s use of his property was not consistent with the previous owner’s nonconforming use. The CEO found no violations. The Board found that the neighbor’s use of the lot did not constitute a change in use but was rather an intensification of the previous use. Plaintiffs appealed to the superior court pursuant to Rule 80B. The court granted the Town’s motion to dismiss, concluding that the Board’s review of the CEO’s decision was advisory and, therefore, unreviewable. The Supreme Judicial Court affirmed, holding that, absent an express provision in the Town’s ordinance stating that Plaintiffs may not appeal, a determination of whether there has been a violation of the ordinance is reviewable on appeal. View "Raposa v. Town of York" on Justia Law

The Supreme Judicial Court vacated the judgment of the the district court granting summary judgment in favor of MaineStream Finance on Jacob Berry’s complaint seeking the return of a 2016 Chevrolet Camaro, holding that summary judgment was improper on the facts of this case.In 2016, MaineStream filed an action against Dwight Moody, Berry’s uncle, to repossess two race cars - including the car called “Outlaw" - that Moody had pledged as collateral in a security agreement. The court found that Moody was the owner of Outlaw and entered a final judgment. In 2017, Berry brought this action against MaineStream, alleging that MaineStream wrongfully seized his 2016 Chevrolet Camaro. The district court granted MaineStream’s motion for summary judgment based on MaineStream’s assertion that, in the 2016 action, the court determined that Moody owned the car and that Berry was barred from seeking relief pursuant to the doctrine of res judicata. The Supreme Judicial Court vacated the judgment, holding that summary judgment was improper because the record did not establish that Outlaw was the same vehicle was the one that was at issue in the instant case. View "Berry v. Mainstream Finance" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder and imposing a forty-five-year sentence of incarceration, holding that the trial court did not err or abuse its discretion in the proceedings below.Specifically, the Supreme Judicial Court held that the trial court (1) did not abuse its discretion in the way it considered alternative suspect evidence; (2) did not abuse its discretion by excluding the opinion testimony of a Maine State Police detective; and (3) did not err in finding that Defendant had waived his religious privilege by repeating to his family members and law enforcement officers portions of statements that he had made to a pastor. View "State v. Fournier" on Justia Law

The Supreme Judicial Court affirmed the portion of the superior court’s order denying Defendant’s special motion to dismiss a multipoint complaint against him pursuant to Maine’s anti-SLAPP statute, holding that the complaint was not based on Defendant’s petitioning activities within the meaning of the anti-SLAPP statute, and therefore, the court did not err by denying Appellant’s special motion to dismiss.Plaintiffs filed a complaint against Defendant alleging defamation, false light, tortious interference with advantageous business relationships, and intentional infliction of emotional distress (IIED). Defendant filed a motion to dismiss pursuant to the anti-SLAPP statute, Me. Rev. Stat. 14, 556. The superior court denied the motion but granted in part Defendant’s motion for partial judgment by dismissing the IIED claim. The Supreme Judicial Court addressed only the denial of Defendant’s special motion to dismiss and affirmed, holding that the superior court correctly determined that a substantial majority of Defendant’s statements and conduct were not petitioning activities within the meaning of the anti-SLAPP statute. View "Hearts with Haiti, Inc. v. Kendrick" on Justia Law

The Supreme Judicial Court affirmed two separate judgments of the probate court granting the petitions of half-sisters’ maternal grandmother to terminate the fathers’ parental rights as part of the proceeding through which the grandmother sought to adopt the children, holding that the fathers were not deprived of due process and equal protection of the law when the court denied the fathers’ motions for an order requiring the provision of rehabilitation and reunification services.The judicial termination proceedings in these consolidated cases did not involve the Department of Health and Human Services. The fathers argued that they were constitutionally entitled to the services that are ordinarily provided in a title 22 child protection action after a court has found abuse or neglect or has placed a child in foster care under the supervision of the Department. The Supreme Court disagreed, holding that the probate court (1) did not violate the fathers’ constitutional rights by denying the fathers’ motions for orders of rehabilitation and reunification services; and (2) did not err in determining that each father’s parental rights should be terminated. View "In re Adoption of Riahleigh M." on Justia Law

The Supreme Judicial Court vacated the judgment of the probate court denying the petition filed by Michael Zani and Peter Zani to be appointed co-guardians of Patricia S., their mother and an incapacitated adult, and instead appointing Karin Beaster and Nancy Carter as co-guardians, holding that Beaster and Carter had not fulfilled the pretrial filing requirements of Me. Rev. Stat. 18-A, 5-303(a).The probate court appointed Beaster and Carter as co-guardians of Patricia even though Beaster and Carter had not filed petitions to be appointed. The Supreme Judicial Court vacated the judgment, holding that the superior court erred by appointing Beaster and Carter when they had not complied with the requirements applicable to a guardianship petition under section 5-303(a). View "In re Patricia S." on Justia Law