Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant’s judgment of conviction for operating under the influence (Class D), holding that the motion court did not err by denying Defendant’s motion to suppress evidence of Defendant’s blood-alcohol level obtained following two warrantless blood draws.On appeal, Defendant argued that the motion court erred in finding that exigent circumstances justified two warrantless blood draws and thus denying his motion to suppress evidence of his blood-alcohol level obtained from the second blood draw. The Supreme Judicial Court disagreed, holding that the evidence supported the motion court’s finding that there were exigent circumstances that negated the warrant requirement for both blood draws. View "State v. Martin" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his child, holding that the record supported the court’s finding of parental unfitness.Specifically, the Court held (1) the district court did not err in finding that, despite Father’s efforts, Father remained unable to protect the child from jeopardy or to take responsibility for the child within a time reasonably calculated to meet the child’s needs; and (2) the district court did not abuse its discretion in determining that termination of Father’s parental rights was in the child’s best interests. View "In re Child of Charles V." on Justia Law

The Supreme Judicial Court affirmed orders of the trial court denying Appellant’s motions to suppress evidence that was seized by the local police department and state police and then returned to the individuals who reported the items stolen, holding that Appellant received a fair trial and that the search warrants were valid.On appeal, Appellant argued that the State failed to preserve exculpatory evidence in violation of his due process right to a fair trial, and that two search warrants failed to designate all of the items to be seized with adequate particularity, making the warrants unconstitutionally vague. The Supreme Judicial Court affirmed, holding (1) even if Appellant made the threshold showing that the evidence at issue was lost or destroyed, he did not demonstrate that any of the evidence had apparent exculpatory value at the time the items were returned to their owners; and (2) the search warrants identified the items to be seized with as much particularity as was possible under the circumstances. View "State v. Winchester" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court dismissing as untimely Appellant’s petition seeking review of a rule promulgated by the Department of Corrections (DOC), holding that the court should have treated Appellant’s petition as a complaint for declaratory judgment and allowed him to amend his petition to that effect.In his petition, Appellant, a prisoner at the Maine State Prison, claimed that the DOC had promulgated and enforced a rule that violated Me. Rev. Stat. 34-A, 3039 and several provisions of the state and federal Constitutions. The superior court dismissed the petition without reaching the merits of Appellant’s statutory and constitutional arguments. The Supreme Judicial Court vacated the judgment, holding that, given Appellant’s clear challenge to the legality of the DOC rule itself and not its application to his individual circumstances, the court abused its discretion in declining to allow Appellant to amend his complaint and seek relief through a declaratory judgment action. View "Sweeney v. Department of Corrections" on Justia Law