Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed the judgment of the trial court granting Appellant’s petition for postconviction relief and vacating his conviction of sexual abuse of a minor, holding that the court’s factual findings were supported by competent evidence in the record.After a hearing, the postconviction court found that Appellant had been deprived of the effective assistance of counsel and vacated his conviction. The Supreme Court affirmed, holding that the postconviction court’s finding that Appellant had been deprived of the effective assistance of counsel at trial was supported by competent record evidence. View "Fahnley v. State" on Justia Law

Clear and convincing evidence supported the district court’s finding that Mother was unfit as a parent, and the district court acted within its discretion in determining that termination of Mother’s parental rights was in the child’s best interest.The district court terminated Mother’s parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a), (B)(2)(a), and (b)(i)-(ii). On appeal, Mother challenged the sufficiency of the evidence supporting the lower court’s findings of parental unfitness and argued that the court was required to order additional time for her to attempt to rehabilitate herself and reunify with the child. The Supreme Court disagreed, holding that the court’s findings were supported by competent evidence in the record, and the court properly exercised its discretion in this case. View "In re Child of Amber L." on Justia Law

The Supreme Judicial Court affirmed a summary judgment entered in the Business and Consumer Docket in favor of Copay Italia S.p.A. on Puritan Medical Products Company’s claim that Copay violated Maine’s Actions for Bad Faith Assertion of Patent Infringement statute, Me. Rev. Stat. 14, 8701-8702, holding that Puritan’s claim was preempted by federal patent law.Although the lower court granted summary judgment for Copan after finding no genuine issues of material fact and determining that Copay was entitled to judgment as a matter of law, Copan filed a cross-appeal challenging the court’s conclusion that Puritan’s claim was not preempted by federal law. The Supreme Judicial Court affirmed, holding (1) in its preemption analysis, the trial court conflated the test for federal preemption with the test for federal jurisdiction; and (2) federal patent law preempted Puritan’s state law claim, and therefore, summary judgment in favor of Copay was properly granted on that basis. View "Puritan Medical Products Co. v. Copan Italia S.p.A." on Justia Law

A Department of Health and Human Services hearing officer erred in concluding that a child support ordered entered in James Fagone’s divorce from Kristin Fagone authorized the Department’s Division of Support Enforcement and Recovery to adjust the amount of child support owed, without a modification of the court order, upon the oldest of the parties’ three children reaching age eighteen.The superior court vacated the hearing officer’s decision, concluding that the child support order entered upon the Fagones’ divorce was not self-adjusting. The Supreme Judicial Court affirmed, holding that the superior court correctly concluded that the order required the payment of support in the amount specified unless and until ordered otherwise and that the hearing officer erred in calculating a reduced amount based on the terms of the existing child support order. View "Department of Health and Human Services v. Fagone" on Justia Law