Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Maine Labor Relations Board in favor of the Fraternal Order of Police (the Union) on Plaintiff’s prohibited practice complaint alleging a breach of the duty of fair representation by the Union on its negotiations with the Town of Madison, holding that the facts found by the Board were supported by substantial evidence in the administrative record.Plaintiff, a member of the Town’s former police department, argued that the Union acted arbitrarily in handling collective bargaining over the impact of the Town’s elimination of its police department. The Board determined that Plaintiff failed to meet his burden of proof. The Supreme Court affirmed, holding that the record did not compel a determination that the Union’s actions and its representatives were so outside a wide range of reasonableness as to be irrational. View "Trask v. Fraternal Order of Police" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part an order of the trial court suppressing evidence seized pursuant to a warrantless search of Defendant’s jacket and vehicle, holding that the search of Defendant’s jacket was a lawful search incident to arrest but that the search of Defendant’s vehicle was not supported by probable cause and was outside the scope of a vehicle search incident to arrest.The trial court concluded that the searches of Defendant’s jacket and vehicles and the seizure of the evidence was not supported by probable cause and violated Defendant’s Fourth Amendment rights. The State appealed, arguing that the search of Defendant’s jacket was a lawful search incident to her arrest and that the evidence discovered in the jacket supported the subsequent search for the illegal drugs discovered in Defendant’s vehicle. The Supreme Judicial Court agreed with respect to the search of Defendant’s jacket but vacated the suppression order as to the evidence found in the vehicle. View "State v. Pagnani" on Justia Law

The Supreme Judicial Court dismissed the appeal brought by the Department of Health and Human Services (Department) from a partial judgment entered in the Business and Consumer Docket mandating the implementation of one provision of the citizen initiative expanding Medicaid coverage.The initiating petition in this case requested numerous forms of relief. The superior court addressed only one component of the requested relief due to ripeness issues. The Supreme Judicial Court decided that it must dismiss this appeal as interlocutory because the petition was not disposed of in its entirety and no exception to the final judgment rule existed. View "Maine Equal Justice Partners v. Commissioner, Department of Health & Human Services" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court denying Jerry Philogene’s motion to set aside a default and for relief from a judgment, holding that Philogene demonstrated excusable neglect.The default judgment in this case extinguished Philogene’s property rights to $16,545 in cash seized as part of a civil asset forfeiture proceeding, initiated following a motor vehicle stop and the filing of criminal charges connected with Philogene’s operation of the vehicle. After entry of the default judgment, Philogene filed a motion to set aside the default and for relief from the judgment. The trial court denied the motion, concluding that Philogene’s assumption that his criminal attorney was representing him in the civil forfeiture matter did not constitute excusable neglect and that Philogene’s claim that he possessed the $16,545 in order to purchase a car for his sister did not constitute a meritorious defense. The Supreme Judicial Court disagreed, holding (1) Philogene showed a reasonable excuse for his inattention to the forfeiture proceedings; and (2) Philogene demonstrated a meritorious defense to the underlying charges. View "State v. Philogene" on Justia Law

At issue was the availability of homeowner’s liability insurance coverage for damages resulting from injuries Jonathan Ben-Ami received after Joshua Francoeur, a fellow high-school student, punched Ben-Ami a number of times in the face.Francoeur was the son of the named insured under a policy issued by Vermont Mutual Insurance Company. The superior court entered a declaratory judgment determining that Francoeur’s tortious conduct did not fall within a policy exclusion from coverage for bodily injury that is “expected or intended,” and therefore, that Ben-Ami was entitled to indemnification under the policy. The Supreme Judicial Court vacated the judgment and remanded for entry of judgment for Vermont Mutual, holding that Francoeur’s specific conduct established that the damages he inflicted on Ben-Ami were “expected” and therefore excluded from coverage by the Vermont Mutual policy. View "Vermont Mutual Insurance Co. v. Ben-Ami" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for four counts of gross sexual assault and other sex offenses, holding that none of Defendant’s assignments of error required reversal.Specifically, the Court held (1) the trial court did not err in denying Defendant’s motion for judgment of acquittal on eight of the eleven counts for which he was convicted because the State is not required to present specific evidence of separate and discrete incidents of abuse for the jury to convict a defendant of every charged offense, as long as the jury is instructed on specific unanimity; (2) Defendant was not unfairly prejudiced by the trial court’s admission into evidence of uncharged sexual abuse; and (3) the trial court did not err in denying Defendant’s motion for judgment of acquittal as to previous unlawful sexual contact charges under the limitations period. View "State v. Reynolds" on Justia Law

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