Justia Maine Supreme Court Opinion Summaries

In this professional negligence action, the Supreme Judicial Court affirmed the judgment of the superior court concluding that Defendant, a medical center, was not negligent when it discharged Plaintiffs’ father, who died the night he was discharged.After a bench trial, the superior court concluded that Defendant was not negligent when it discharged the decedent over the objection of his guardians and that the discharge plan met the standard of care. The Supreme Judicial Court affirmed, holding that the superior court (1) did not err in concluding that, at the time he was discharged, Defendant had regained capacity to make his own health-care decisions and that Defendant’s discharge plan met the standard of care; and (2) did not err in denying Defendant’s request for costs for expert witness fees and expenses incurred during the prelitigation screening panel process. View "Oliver v. Eastern Maine Medical Center" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Secretary of State to impose a three-year administrative suspension of Appellant’s driver’s license based on a fatal accident that he caused.In 2014, the vehicle Appellant was driving crossed the center line and collided with an oncoming vehicle, causing the deaths of two passengers in his vehicle. In 2016, the Secretary of State sent Appellant a notice of suspension advising him that, in accordance with Me. Rev. Stat. 29-A, 2458(2-A), his driver’s license would be suspended for three years. The Hearing Examiner upheld the suspension, finding that Appellant negligently operated a motor vehicle when he fell asleep while driving and swerved into oncoming traffic, causing the deaths of two people. The superior court affirmed. The Supreme Judicial Court affirmed, holding (1) section 2458(2-A) is not so punitive as to be a criminal prosecution and therefore does not require a higher standard of proof; and (2) there was sufficient evidence to support the three-year suspension. View "Richard v. Secretary of State" on Justia Law

The Supreme Judicial Court vacated a judgment of foreclosure entered by the district court in favor of M&T Bank following a nonjury trial on M&T Bank’s complaint and remanded for entry of a judgment in favor of Lawrence Plaisted, holding (1) M&T Bank failed to lay a proper foundation for admitting loan servicing records pursuant to the business records exception to the hearsay rule, and (2) M&T Bank failed to prove the amount owed on the note.On appeal, Plaisted argued that the court abused its discretion by admitting Exhibit E pursuant to the business records exception to the hearsay rule and erred in concluding that M&T Bank proved the amount owed on the note. The Supreme Judicial Court agreed, holding that M&T Bank failed to meet its burden of proving the amount owed by presenting evidence of information regarding the original amount of the loan, the total amount paid by the mortgagor, and other information in a form that was both accessible and admissible. View "M&T Bank v. Plaisted" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting motions to dismiss and motions for summary judgment in an order that resulted in judgment for all defendants on Plaintiff’s complaint, holding that the proceedings below were without error.Plaintiff filed this action against judges and other court employees, the Board of Overseers of the Bar, the Maine Commission in Indigent legal Services, and the Lewiston Sun Journal challenging Defendants’ actions in an attorney disciplinary proceeding before the Board that resulted Defendant’s two-year suspension from the practice of law with conditions imposed on Plaintiff’s practice. Plaintiff’s complaint asserting numerous causes of action and allegations against Defendants. The superior court entered judgment for Defendants. The Supreme Judicial Court affirmed, holding that the superior court did not err in ruling that (1) most defendants were protected by statutory or common law immunities, (2) there were no disputes of fact regarding Plaintiff’s claims against Defendants, and (3) Defendants were entitled to judgment as a matter of law. View "Carey v. Board of Overseers of the Bar" on Justia Law

The Supreme Judicial Court dismissed this appeal challenging the promulgation of a final rule by the Public Utilities Commission, holding that this Court does not have original jurisdiction over appeals from administrative rulemaking proceedings.Appellants, including the Conservation Law Foundation, the Industrial Energy Consumers’ Group, ReVision Energy, LLC, and the Natural Resources Council of Maine, argued, among other things, that, in promulgating the rule at issue, the Commission violated several provisions of the Maine Administrative Procedure Act, that the rule violated statutory ban on exit fees, and that the rule unjustly discriminated. The Commission argued that Me. Rev. Stat. 35-A, 1320 does not authorize appeals to the Law Court when the Commission acts pursuant to its rulemaking authority. The Supreme Judicial Court agreed, holding that any appeal from Commission rulemaking proceedings must be brought originally in the Superior Court. View "Conservation Law Foundation v. Public Utilities Commission" on Justia Law

In this interlocutory appeal, the Supreme Judicial Court remanded the matter without reaching the merits of the appeal, holding that the discovery order challenged on appeal was now a nullity and did not govern future proceedings in this case and that no exception to the final judgment applied.Appellants appealed from an order of the superior court granting Appellee’s motion to compel them to produce in discovery certain patient medical records that the court found to relevant to Appellees' notice of claim asserting medical negligence. The Supreme Judicial Court held (1) given the unusual procedural posture presented in this case, the discovery order was a nullity without legal force or effect and did not govern future proceedings in this case; and (2) no exception to the final judgment rule applied that would require the Court to reach the merits of the parties’ arguments below. View "McCain v. Vanadia" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court, sitting as the juvenile court, that adjudicated J.R. of having committed two counts of criminal mischief and three counts of theft, holding that the district court acted within its discretion.Specifically, the Court held (1) the court did not abuse its discretion or otherwise err in determining that commitment to a secure juvenile correctional institution was the least restrictive dispositional alternative, absent any explicit finding that J.R.’s commitment was necessary to protect the public; and (2) J.R.’s indeterminate commitment until age eighteen did not offend constitutional principles of proportional punishment. View "State v. J.R." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of ten charges, including two counts of intentional or knowing murder, holding that the trial court did not err by allowing the jury to consider certain identification testimony.On appeal, Defendant argued that the trial court erred in denying his motion in limine that sought to exclude the identification testimony because the out-of-court identification was produced by an impermissibly suggestive procedure, rendering the testimony unreliable. The Supreme Judicial Court held that the witness’s out-of-court identification was independently reliable, and therefore, the court did not abuse its discretion in admitting the identification testimony. View "State v. Davis" on Justia Law

In this divorce proceeding, the Supreme Judicial Court vacated the district court’s child support order but affirmed the divorce judgment in all other respects, holding that the record did not support the factors used by the court for a downward deviation from Father’s presumptive child support obligation and did not support the court’s determination that the presumptive amounts of child support as calculated pursuant to the child support guidelines, see Me. Rev. Stat. 19-A, 2006, were inequitable or unjust.The Court further held (1) the court did not abuse its discretion in its award of spousal support; and (2) the court did not abuse its discretion by declining to award attorney fees beyond those provided through an interim order. The First Circuit remanded for entry of a child support order pursuant to the guidelines and otherwise affirmed. View "Sullivan v. George" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for aggravated trafficking of scheduled drugs following his guilty plea, holding that the motion court did not err in denying Defendant’s motion to suppress evidence seized by, and statements made to, police officers after he was arrested without a warrant.On appeal, Defendant argued that the police lacked sufficient probable cause to believe that he was engaged in criminal conduct to justify his warrantless arrest. Therefore, Defendant argued, the statements made and evidence seized after the arrest were subject to suppression. The Supreme Judicial Court disagreed, holding (1) sufficient corroborated information warranted any prudent and cautious person to believe that Defendant was committing the offense of heroin trafficking; and (2) therefore, law enforcement officers properly made the warrantless arrest. View "State v. Journet" on Justia Law