Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant’s conviction of twenty-eight counts of gross sexual assault, holding that the evidence was sufficient to convict Defendant of each count of gross sexual assault.Defendant was convicted by a jury for acts committed on the victim, his biological daughter. On appeal, Defendant argued that the State did not produce sufficient evidence from which the jury could have found that he committed each of the twenty-eight counts of gross sexual assault for which he was convicted. After noting that the focus of Defendant’s argument was that the State was required to produce evidence regarding the time and place of each individual incident of assault the Supreme Judicial Court affirmed, holding (1) time and place are not essential elements of gross sexual assault; and (2) the State proved each and every element of all twenty-eight counts of gross sexual assault. View "State v. Miller" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for violating a public safety fire rule, holding that Defendant’s arguments on appeal were unavailing.Defendant was convicted of failing to comply with section 24.2.2.3.3 of the 2009 edition of the National Fire Protection Association 101: Life Safety Code, as incorporated by rule by the Commissioner of the Department of Public Safety. The Supreme Judicial Court affirmed the judgment of conviction, holding (1) section 24.2.2.3.3 of the Life Safety Code is not void for vagueness; (2) the trial court did not abuse its discretion in determining that the State’s failure to provide Defendant with a policy statement regarding the enforcement of section 24.2.2.3.3 did not constitute a Brady violation; and (3) the evidence was sufficient to support Defendant’s conviction. View "State v. Nisbet" on Justia Law

The Supreme Judicial Court held that an individual resident of Maine was not entitled to a Maine income tax credit for any portion of business taxes imposed by New Hampshire on a New Hampshire limited liability company of which the Maine resident was a member.Appellants, Maine residents, appealed from the judgment of the Business and Consumer Docket affirming the State Tax Assessor’s denial of a tax credit for a share of a New Hampshire business taxes paid by a New Hampshire LLC proportional to the membership interest that Appellants had in the LLC. The court reasoned that no income tax credit applied because (1) the New Hampshire business taxes were imposed on the LLC and were not an “amount of income tax imposed on [an] individual,” Me. Rev. Stat. 36, 5217-A; and (2) Maine’s tax statutes do not violate the Commerce Clause of the federal Constitution. The Supreme Judicial Court affirmed, holding (1) the lower court correctly interpreted Maine’s income tax statutes; and (2) the court did not err in concluding that Maine’s tax statutes are constitutionally sound. View "Goggin v. State Tax Assessor" on Justia Law

At issue was whether a defendant who has conditions of release set by a judicial officer can be convicted of violation of a condition of release for acts committed while in jail after not securing release on bail.Defendant was convicted of twelve counts of violating a condition of release. On appeal, Defendant argued that the conditions of release order did not apply to him because he had failed to post bail and had not been released from jail to make the conditions of release applicable. Defendant further argued that he was not provided with adequate notice of the conditions of release or of the penalties for violating conditions of release while he remained incarcerated, as required by Me. Rev. Stat. 15 1026(5). The Supreme Judicial Court vacated the judgment of the trial court, holding (1) the conditions of release order, by law, was effective when entered at the initial appearance hearing; but (2) there was insufficient evidence that Defendant was provided with notice of the conditions of release applicable to him while he was in jail. View "State v. Leblanc-Simpson" on Justia Law