Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed the judgments entered by the probate court terminating Father’s parental rights to his two children in anticipation of an adoption, holding that the court did not err in its use of statements made by one of the children during an in camera interview and that there was sufficient evidence to support the court’s finding of parental unfitness as to both children.The probate court terminated Father’s parental rights pursuant to Me. Rev. Stat. 18-A, 9-204(a)-(b) and Me. Rev. Stat. 22, 4055(1)(A)(2), (B)(2)(a) and (B)(2)(b)(ii). The Supreme Judicial Court affirmed, holding (1) any errors made by the probate court with regard to statements given by S.S. during the in camera interview were harmless; (2) the evidence was sufficient to support the court’s findings; and (3) Father was not deprived of a fair trial or treated unjustly as a result of the trial court’s erroneous sequence of its fact-finding. View "In re Adoption of Shayleigh S." on Justia Law

The Supreme Court vacated the judgment of the superior court affirming the decision of the Department of Health and Human Services to deny John Doe’s request for a review of the Department’s 2003 substantiation of him for sexual abuse of a minor, holding that the Department’s denial of Doe’s request as untimely violated Doe’s procedural due process rights.In 2003, the Department mailed a letter to Doe informing him that he had been substantiated for sexual abuse of a minor. When the Department substantiated Doe, a paper review established by a 2000 Department policy was the only appeal process available to an individual seeking to challenge a substantiation fining. The Department did not adopt the 2000 policy pursuant to the Maine Administrative Procedure Act (APA). In 2017, the Department notified Doe that, based on his 2003 substantiation, his presence in a home where children were residing could lead to the removal of those children. Doe requested a hearing to review his 2003 substantiation, but the Department denied the request as untimely. The superior court affirmed. The Supreme Judicial Court vacated the judgment, holding that the Department’s 2000 policy was judicially unenforceable, the 2003 Department letter constitutionally flawed, and the Department’s denial of Doe’s request as untimely a violation of Doe’s procedural due process rights. View "Doe v. Department of Health & Human Services" 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)(A)(1)(a), holding that the court’s findings were supported by competent in the record and were sufficient to support the court’s decision.Specifically, the Court held that the the court’s findings supported the court’s determination that (1) Mother was unable to protect the child from jeopardy and was unwilling or unable to take responsibility for the child within a time reasonably calculated to meet the child’s needs; (2) Mother failed to make a good faith effort to rehabilitate and reunify with the child; and (3) termination of Mother’s parental rights was in the child’s best interests. View "In re Child of Stephenie F." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder and possession of a firearm by a prohibited person, holding that the court did not err in the way it conducted voir dire and that the admission into evidence of two burglary convictions pursuant to Me. R. Evid. 609 was not an abuse of the court’s discretion.Specifically, the Court held that the trial court (1) did not abuse its discretion by not including in the juror vote dire questionnaire six of Defendant’s proposed juror questions and by not giving the prospective jurors the option of answering any of the questions with “not sure” as an alternative to “yes” or “no”; and (2) did not abuse its discretion by admitting evidence of two prior burglary convictions to impeach Defendant’s trial testimony. View "State v. Burton" on Justia Law