Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence (OUI) with one prior OUI offense, holding that the court did not abuse its discretion during the proceedings below.On appeal, Defendant argued that the court abused its discretion when it ordered that the State would be permitted to use a challenged video recording to impeach Defendant if he testified and contradicted what the video showed, despite the court’s order sanctioning the State by excluding the recording from the State’s case-in-chief. The Supreme Court disagreed, holding (1) the State’s failure to provide Defendant with the recording it intended to offer in evidence within seven days after his plea of not guilty constituted a violation of M.R.U. Crim. P. 16(a)(2)(C); but (2) the court acted within its discretion in declining to exclude the video altogether, and the sanction did not deprive Defendant of a fair trial. View "State v. Matatall" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her youngest child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (1)(B)(2)(a), (b)(i)-(iv), holding that the court did not deny Mother due process, did not err when it found Mother unfit, and did not abuse its discretion when it determine that terminating her parental rights was in the best interest of the child.On appeal, Mother contended, among other things, that she was denied due process when the district court conducted an evidentiary hearing in her absence on the petition to terminate her parental rights. The Supreme Judicial Court disagreed, holding (1) under the circumstances of this case, the district did not deprive Mother of due process where Mother was voluntarily absent without good cause during the evidentiary hearing not he termination petition; and (2) the court did not err in finding that Mother was unfit or abuse its discretion in concluding that termination of Mother’s parental rights was in the best interests of the child. View "In re Child of Tanya C." on Justia Law

In this dispute over the location of the boundary between the land of Appellees and the land of Appellants, the Supreme Judicial Court affirmed the judgment of the superior court declaring the location of that boundary line, holding that the superior court did not err or abuse its discretion.On appeal, Appellants generally challenged the discretionary decisions made by the trial court in its management of the proceeding. The Supreme Judicial Court denied the challenges, holding that, contrary to Appellants’ contentions, the trial court did not err or abuse its discretion either in its case management orders or in its findings and conclusions. View "Gammon v. Boggs" on Justia Law

The Supreme Judicial Court affirmed the judgment of the probate court appointing the Department of Health and Human Services as David P.’s limited public guardian pursuant to Me. Rev. Stat. 18-A, 5-601, holding that any error on the part of the probate court was harmless and that there was sufficient competent evidence in the record to support the probate court’s judgment.On appeal, David argued that there was insufficient evidence to support the probate court’s decision and that the court erred in admitting a written report drafted by a psychologist in violation of the rule against hearsay. The Supreme Judicial Court held (1) it was error for the probate court to admit the psychologist’s written report in its entirety, but the error was harmless; and (2) the evidence was sufficient to support the judgment. View "Guardianship of David P." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Mother and Father to their child pursuant to me. Rev. Stat. 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv), holding that the district court did not abuse its discretion.Specifically, the Court held (1) the district court did not err in its parental unfitness finding as to Father; (2) the district court did not deny Father due process of law when it based its findings of unfitness, in part, on Father’s unprescribed use of prescription drugs as stimulants; and (3) the district court did not err in determining that termination of Mother’s parental rights, with a permanency plan of adoption, was in the best interest of the child. View "In re Child of Troy C." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s and Father’s parental rights to their child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii), (iv), holding that the district court did not abuse its discretion.Specifically, the Court held (1) the district court did not abuse its discretion by denying Mother’s motion to continue the termination hearing and appoint a guardian ad litem; and (2) the evidence was sufficient to support the district court’s determinations that Father was an unfit parent within the meaning of the child protection statutes and that termination was in the child’s best interest. View "In re Child of Mercedes D." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Appellant’s parental rights to his son, holding that the court did not err or abuse its discretion in finding that the factors supported termination and that termination of Father’s parental rights was in the child’s best interest.Specifically, the Supreme Judicial Court held that the court did not err or abuse its discretion in finding (1) Father was unwilling or unable to protect the child from jeopardy and that those circumstances were unlikely to change within a time reasonably calculated to meet the child’s needs under Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i); and (2) termination of Father’s parental rights was in the child’s best interest. View "In re Child of Matthew R." on Justia Law

At issue was whether evidence of the factual circumstances underpinning Defendant’s prior manslaughter conviction was admissible to establish an enhancing factor necessary to convict Defendant of the Class B offense of operating a motor vehicle while under the influence of intoxicants (OUI).Defendant was indicted for aggravated criminal OUI. The indictment alleged that the enhancing factor was Defendant’s 1991 manslaughter conviction that involved the operation of a vehicle while under the influence of intoxicants. The Supreme Judicial Court vacated the order of the unified criminal docket granting Defendant’s motion in limine to exclude evidence of his alleged intoxication at the time he committed his manslaughter offense. The Court held that the trial court erred when it ruled that the State’s proof regarding Defendant’s prior conviction was limited to the face of the prior indictment and judgment and commitment, which did not establish that Defendant was operating while under the influence at the time of the homicide. The Court then vacated the order granting the motion in limine and remanded for entry of an order denying the motion. View "State v. Hastey" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s and Father’s parental rights to their two older children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), holding that the evidence was sufficient to support the determination of parental unfitness and that the court did not err by concluding that termination of the parents’ parental rights was in the best interests of the children.Specifically, the Court held (1) competent evidence in the record existed to support both of the two types of parental unfitness found by the district court; and (2) the court’s findings, based on clear and convincing evidence in the record, were sufficient to support its determination that the termination of each parent’s parental rights was in the best interests of the children. View "In re Children of Anthony M." on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of the Town of Glenburn on its land use violation complaint but vacated the civil penalty imposed by the district court, holding that the record was devoid of any evidence of one of the factors that Me. Rev. Stat. 30-A, 4452(3)(E) requires the court to consider.The land use violation complaint in this case was filed pursuant to Me. Rev. Stat. 30-A, 4452 and Me. R. Civ. P. 80K. The Supreme Court vacated the civil penalty but otherwise affirmed, holding (1) the district court did not violate Appellant’s procedural due process right by allowing one of the Town’s witnesses to testify by telephone; (2) the district court did not err by not excluding, sua sponte, testimony from the Town’s Code Enforcement Officer concerning a witness’s two out-of-court statements; and (3) on the evidence before it, the district court could not have considered the extent to which the violations on the property may have continued after notification to Appellant - a factor that must be considered by the court before assessing a civil penalty. View "Town of Glenburn v. Pinkham" on Justia Law