Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated operating under the influence and aggravated assault, holding that the court did not err in denying Defendant’s motion to suppress evidence of his alcohol level determined from a sample of Defendant’s blood that was seized without a warrant.Specifically, the Court held (1) probable cause existed for a law enforcement officer to obtain a sample of Defendant’s blood in the context of an operating under the influence investigation, and (2) exigent circumstances justified the warrantless blood draw because Defendant was about to go into surgery where he would not be available for a blood draw as part of the State’s investigation and his body would further metabolize any alcohol that might be in his blood. View "State v. Palmer" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his child pursuant to Me. Rev. Stat. 4055(1)(A)(1)(a) and (B)(2)(a), (b)(ii), holding that the evidence supported the court’s factual findings and that the court did not exceed its discretion in determining that termination of Father’s parental rights was in the child’s best interest.On appeal, Father argued primarily that the lower court impermissibly relied on his incarceration to find parental unfitness and the child’s need for permanency in determining the child’s best interest. The Supreme Court disagreed, holding that the court’s material findings were supported by competent evidence in the record, that the court did not impermissibly consider Father’s incarceration in reaching its parental unfitness determination, and that the evidence supported the court’s finding of parental unfitness. Further, the court did not abuse its discretion by considering the child’s needs for stability and permanency in finding parental unfitness and in determining that termination of Father’s parental rights was in the child’s best interest. View "In re Child of Ronald W." on Justia Law

The Supreme Court held that the statutory notification process necessary for a conviction for operating after habitual offender revocation is not satisfied where the Secretary of State elects to mail the notification of license revocation to the licensee’s most recent address on file with the Secretary of State pursuant to Me. Rev. Stat. 29-A, 2557-A(1)(A)(4), and that notification is returned by postal officials as undeliverable.The Supreme Court vacated Defendant’s conviction for operating after habitual offender revocation where (1) in 2004, the Secretary of State mailed a notice to Defendant’s last known address notifying him that his right to operate a motor vehicle was about to be revoked and that letter was returned by postal authorities to the Secretary of State’s office, and (2) more than eleven years later, Defendant was charged with operating after habitual offender revocation. Therefore, the evidence was insufficient to support the determination that Defendant received or otherwise had actual knowledge of the revocation. View "State v. Cannady" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court in favor of the Town of Mount Vernon on its land use violation complaint filed pursuant to Me. Rev. Stat. 30-A, 4452 and Me. R. Civ. P. 80K, holding that a generator on Landowners’ property was a structure and thus must meet the requirements of the Town’s Land Use Ordinance regarding structures.On appeal from a decision of the Town’s code enforcement officer, the Mount Vernon Board of Appeals determined that a relatively large generator that Landowners had installed on their small lot was a “structure” under the Ordinance. When Landowners failed to comply with the Towns’ request for the removal of the generator, the Town filed a land use violation complaint. The district court determined that the Board’s decision was res judicata as to whether the generator met the definition of “structure” in the Ordinance and found Landowners in violation of the Ordinance, assessing penalty and attorney fees. The Supreme Judicial Court affirmed, holding (1) the district court correctly determined that the Board’s decision was binding on Landowners; and (2) the court did not err in finding that Landowners were in violation of the Ordinance and assessing a penalty. View "Town of Mount Vernon v. Landherr" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court modifying Father’s child support obligation to Mother regarding the parties’ minor child, holding that the court had authority to modify child support but erred in its calculations.On appeal, Appellant argued that the court erred by modifying the existing child support order because the issue was not raised by either party and that the court erred both by addressing the issue and in its calculations. The Supreme Judicial Court held (1) the issue of child support was sufficiently raised in response to a motion to modify such that Father had sufficient notice that his child support obligation may change, and therefore, the district court had the authority to modify the child support order; and (2) the court erred in its calculations, thus exceeding the bounds of its discretion in ordering Father to pay the determined child support. The Court remanded the case for the trial court to calculate and order the correct amount of child support. View "Petersen v. Overbeke" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Unified Criminal Docket convicting Defendant of violating a protection order, holding that Defendant’s posts on his Facebook page, including threatening ones, directed at the protected person violated the protection order.Defendant was enjoined by a protection from abuse order from having direct or indirect contact with the protected person. The State later charged Defendant with violating the protection order because Defendant had published several posts on Facebook concerning the protected person, and the content of the posts was “obviously offensive.” The court found Defendant guilty of violating the protection order. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in finding that the entries Defendant posted on Facebook did not constituted “direct or indirect contact” with the protected person; (2) Defendant had sufficient notice that the posts were a form of proscribed conduct; and (3) the trial court correctly determined that a conviction based on Defendant’s violation of the protection order did not place Defendant's First Amendment rights at risk. View "State v. Heffron" on Justia Law

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