Justia Maine Supreme Court Opinion Summaries

The “prisoner mailbox rule” applies when a prisoner is forced to rely on the Department of Corrections to ensure that his Me. R. Civ. P. 80C petition is filed, that prisoner places the petition into the control of the Department, and the Department fails timely to deliver the petition to the clerk of court.Petitioner signed a petition pursuant to Me. Rev. Stat. 5, 11002 for judicial review of a Department decision finding that he had committed a disciplinary infraction. The State moved to dismiss the petition for failure to state a claim, arguing that because the clerk of court received Petitioner’s petition one day outside of the thirty-day statutory window, the superior court lacked jurisdiction over the matter. Petitioner urged the superior court to apply the prison mailbox rule, whereby the court would consider the petition filed on the date Petitioner deposited it with prison officials for forwarding to the clerk of court rather than the day it was received by the clerk of court. The court granted the State’s motion to dismiss. After setting forth the circumstances above under which the prisoner mailbox rule applies the Supreme Judicial Court adopted the prison mailbox rule for any unrepresented prisoner under the circumstances of this case, vacated the judgment, and remanded to the superior court for reinstatement of the Rule 80C petition. View "Martin v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court denying Benton, LLC’s motion for summary judgment and rejecting its claim that section 104 of the Maine Workers’ Compensation Act of 1992, Me. Rev. Stat. 39-A, 104, provided it with immunity from Chauncey Clark’s negligence suit for injuries sustained on Benton, LLC’s property in Benton, Maine.On appeal, Benton, LLC argued that an extension of the dual persona doctrine regarding the scope of the Act’s immunity and exclusivity provisions provided it with immunity from Clark’s suit as a matter of law. Specifically, Benton, LLC argued that once Clark’s actual employer secured workers’ compensation for Clark’s injuries and lost wages, section 104 of the Act immunized the employer and Benton, LLC from Clark’s negligence action because those entities were “functionally one and the same.” The Supreme Judicial Court disagreed, holding that the superior court did not err as a matter of law by determining that the dual persona doctrine’s exception to an employer’s immunity was inapposite to the assertion of immunity by Benton, LLC. View "Clark v. Benton, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court finding that Plaintiff was abused by Defendant and granting a two-year extension of a protection from abuse order to Plaintiff.The Court held (1) the trial court did not abuse its discretion in finding abuse and extending the original protection from abuse order; (2) the trial court gave Defendant sufficient notice of the issues to be addressed in the hearing on the extension of the original order; and (3) there was sufficient evidence to justify extension of the protection from abuse order for two years, with the addition of prohibitions that by federal law had the effect of prohibiting Defendant from possessing firearms that included an express directive prohibiting his possession of firearms. View "Doe v. Tierney" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction of manslaughter entered in the trial court, following a jury trial, holding that Defendant’s contentions of error were unavailing.Specifically, the Court held (1) the trial court did not err in denying Defendant’s motion to suppress statements she made to law enforcement officers during five different interviews; (2) the trial court did not err in instructing the jury on concurrent causation; and (3) the evidence was sufficient to support the jury’s conclusion, beyond a reasonable doubt, that Defendant caused the death of her infant son. View "State v. Hopkins" on Justia Law

At issue was whether, when the defendant has caused a physical invasion of the plaintiff’s property, the plaintiff must present evidence of a specific diminution in market value in order to successfully prove nuisance.An oil tanker owned and operated by Defendant overturned, resulting in more than 9,000 gallons of oil and kerosene spilled from the tanker and onto property belonging to Plaintiffs. The superior court entered judgment upon a jury verdict awarding Plaintiffs compensatory damages in the amount of $490,000 on Plaintiffs’ claim of nuisance. On appeal, Defendant argued that the trial court erred when it denied Defendant’s motions for judgment as a matter of law on the nuisance claim because Plaintiffs did not present any evidence of a specific diminution in market value of their land due to the spill. The Supreme Judicial Court affirmed, holding (1) Plaintiffs in this case did not need to show a specific depreciation in the market or rental value of the land, and therefore, the trial court did not err when it denied Defendant’s motions for judgment as a matter of law on the nuisance claim; and (2) the trial court did not err when it allowed Plaintiffs to introduce evidence of the conduct of Defendant’s insurer at trial. View "West v. Jewett & Noonan Transportation, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated trafficking in schedule W drugs, in violation of Me. Rev. Stat. 17-A, 1105-A(1)(D), holding that section 1105-A(1)(D) does not require the State to prove the weight of “pure” cocaine base.On appeal, Defendant argued that the statute required the State to prove the weight of pure cocaine base in isolation and that the trial court erred in failing to include that requirement in its instructions to the jury. The Supreme Judicial Court disagreed, holding (1) section 1105-A(1)(D) does not require the State to prove the weight of “pure” cocaine base; and (2) the court did not err when it instructed the jury that “[c]ocaine base includes any mixture or preparation that contains any quantity of cocaine base, which is the alkaloid base of cocaine.” View "State v. McLaughlin" on Justia Law

The Supreme Judicial Court affirmed the determination of the superior court that Plaintiffs’ Me. R. Civ. P. 80B petition was moot, vacated the declaratory judgment entered by the court, and remanded for dismissal of the complaint in its entirety.At issue was the decision of the Town of Brunswick to sell certain property. Brunswick residents began initiative proceedings to enact an ordinance that would require the Town to retain the parcel for public use. After the requisite number of signatures were obtained, the town council decided to take no further action on the petition. Plaintiffs filed a Rule 80B petition for review of the council’s decision and sought a declaration that the town charter permits voters to enact, by initiative, an ordinance that would overturn the council’s decision to sell the property. The superior court concluded that the Town erred in declining to hold a public hearing on the proposed ordinance but determined that the issue had been rendered moot by the sale of property. The court then entered a declaratory judgment that the voters could not override the council's vote to sell the property. The Supreme Judicial Court held that the lower court correctly determined the Rule 80B petition to be moot and should have done the same regarding the declaratory judgment action. View "Brunswick Citizens for Collaborative Government v. Town of Brunswick" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court finding jeopardy as to two of Mother’s children pursuant to Me. Rev. Stat. 22, 4035 and ordering the Department of Health and Human Services to cease reunification efforts pursuant to Me. Rev. Stat. 22, 4041(2)(A-2).The Court held (1) the district court did not err when it concluded that the doctrine of res judicata did not bind the Department to orders issued by the probate court concluding that the children were not in jeopardy; (2) Mother’s due process rights were not violated in this case; and (3) the district court’s findings were supported by competent evidence in the record that could rationally be understood to establish as more likely than not that the children were in circumstances of jeopardy to their health and welfare. View "In re Children of Bethmarie R." on Justia Law

The Supreme Judicial Court held that the trial court did not err in determining that the State did not engage in purposeful discrimination when it used a peremptory challenge that excluded from the jury the sole person of color in the jury pool.The Supreme Judicial Court affirmed the judgment of conviction entered in the Unified Criminal Docket convicting Defendant of reckless conduct with a dangerous weapon and criminal threatening with a dangerous weapon. On appeal, Defendant, who described himself as an African American male, argued that the State engaged in purposeful discrimination when it peremptorily challenged the juror at issue. The Supreme Judicial Court disagreed, holding that the trial court did not err when it determined that the prosecutor did not engage in purposeful discrimination. View "State v. Hollis" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Father and Mother (together, Parents) to their son pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii).On appeal, Parents challenged the sufficiency of the evidence supporting the district court’s findings of unfitness and best interest and the court’s discretionary determination that termination of parental rights was in the child’s best interest. The Supreme Judicial Court held (1) the evidence supported the court’s factual findings and discretionary determinations; and (2) the court did not abuse its discretion in determining that termination of Parents’ parental rights was in the child’s best interest. View "In re Child of Everett S." on Justia Law