Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court terminating Parents’ parental rights to their two children and denying their motions to reopen the record and for relief from judgment.On appeal, Parents asserted that the district court erred by denying their motion to reopen the evidence and by denying their motion under Me. R. Civ. P. 60(b). The Supreme Court held (1) the circuit court had no discretion to reopen the evidence as to certain testimony, and the court did not abuse its discretion when it denied Parents’ motion to reopen to present evidence that Parents claimed was relevant to the issues of parental unfitness and the children’s best interests; and (2) the court did not err by determining that, at an earlier termination hearing, Mother was not prejudiced by her attorney’s ineffective representation and that Father’s counsel’s performance was not deficient in the first place. View "In re Children of Jeremy A." on Justia Law

The Supreme Judicial Court affirmed the district court’s grant of partial summary judgment in favor of Avis Rent A Car System, LLC on Avis’s claim for breach of contract but vacated the court’s award of damages.Defendant, a Maine resident, rented a car from an Avis location in Las Vegas, Nevada. The vehicle was damaged when it was involved in an accident in Las Vegas. When Defendant refused to pay for the damages, Avis filed a complaint against Defendant, alleging breach of connect and negligence. The district court concluded that Avis was entitled to partial summary judgment on the breach of contract claim as a matter of law. After an evidentiary hearing, the court granted Avis its requested amount of $15,342 and also awarded attorney fees and costs. The Supreme Judicial Court reversed in part, holding that partial summary judgment as to liability was correctly granted but because Avis presented no admissible evidence as to the amount of damages, it failed to prove it was entitled to the damages awarded to it. The Court then remanded the case for an award of nominal damages in accordance with Nevada law. View "Avis Rent A Car System, LLC v. Burrill" on Justia Law

The Supreme Judicial Court affirmed the district court’s grant of partial summary judgment in favor of Avis Rent A Car System, LLC on Avis’s claim for breach of contract but vacated the court’s award of damages.Defendant, a Maine resident, rented a car from an Avis location in Las Vegas, Nevada. The vehicle was damaged when it was involved in an accident in Las Vegas. When Defendant refused to pay for the damages, Avis filed a complaint against Defendant, alleging breach of connect and negligence. The district court concluded that Avis was entitled to partial summary judgment on the breach of contract claim as a matter of law. After an evidentiary hearing, the court granted Avis its requested amount of $15,342 and also awarded attorney fees and costs. The Supreme Judicial Court reversed in part, holding that partial summary judgment as to liability was correctly granted but because Avis presented no admissible evidence as to the amount of damages, it failed to prove it was entitled to the damages awarded to it. The Court then remanded the case for an award of nominal damages in accordance with Nevada law. View "Avis Rent A Car System, LLC v. Burrill" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant, after a jury trial, of domestic violence assault and violating a condition of release, holding that certain errors in the jury instructions constituted obvious error.On appeal, Defendant argued that the trial court erred by failing fully to instruct the jury on the State’s burden to disprove the statutory justifications Defendant produced in defense of the charges or on the consequences of the State’s failure to meet that burden. The Supreme Judicial Court agreed that the trial court’s instructions were deficient, holding that the errors in the jury instructions were highly prejudicial, tending to produce manifest injustice. View "State v. Villacci" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant, after a jury trial, of domestic violence assault and violating a condition of release, holding that certain errors in the jury instructions constituted obvious error.On appeal, Defendant argued that the trial court erred by failing fully to instruct the jury on the State’s burden to disprove the statutory justifications Defendant produced in defense of the charges or on the consequences of the State’s failure to meet that burden. The Supreme Judicial Court agreed that the trial court’s instructions were deficient, holding that the errors in the jury instructions were highly prejudicial, tending to produce manifest injustice. View "State v. Villacci" on Justia Law

The Supreme Judicial Court affirmed the district court’s judgment terminating Mother’s parental rights to her child.On appeal, Mother argued that the district court erred in determining that the termination of her parental rights was in the child’s best interest when the child was placed in a permanency guardianship with his paternal grandparents and Father’s parental rights were not terminated. The Supreme Judicial Court disagreed, holding that the court did not err or abuse its discretion in finding unfitness and determining that termination of Mother’s parental rights was in the child’s best interest, despite the establishment of a permanency guardianship and Father’s retention of his parental rights. View "In re Child of Emily K." on Justia Law

The Supreme Court held that a bail condition order prohibiting Defendant from possessing a “dangerous weapon” issued by a New Hampshire bail commissioner was a “similar order issued by a court…of another state” pursuant to Me. Rev. Stat. 19-A 4011(1)(A), and therefore, the State could prosecute Defendant for an alleged violation of that order.Defendant filed a motion to dismiss charges against him for violating a protective order. The trial court granted the motion to dismiss, concluding that any alleged violation in Maine of the New Hampshire conditions order could not subject Defendant to prosecution because the order failed to meet the definition of a “similar order” of protection “issued by a court…of another state” pursuant to section 4011(a)(A). The Supreme vacated the judgment and remanded the case to the trial court, holding that the New Hampshire order was a “similar order” under the statute. View "State v. Blum" on Justia Law

The Supreme Judicial Court vacated the decision of the Appellate Division affirming the order of the Workers’ Compensation Board (Board) requiring Plaintiff’s former employer (Defendant) to pay for medical marijuana used to treat Plaintiff’s chronic back pain.Plaintiff was issued a certification to use medical marijuana to treat his pain after sustaining a work-related injury. Plaintiff filed a “petition for payment of medical and related services” with the Board seeking payment from Defendant for the cost of the medical marijuana. Defendant opposed the petition, arguing that an order requiring it to pay for Plaintiff’s medical marijuana was barred by the federal Controlled Substances Act (CSA) even if his use of medical marijuana were permitted by the Maine Medical Use of Marijuana Act (MMUMA). A hearing officer granted Plaintiff’s petition, and the Appellate Division affirmed. The Supreme Court vacated the decision of the Appellate Division, holding (1) in the narrow circumstances of this case, there was a positive conflict between federal and state law; and (2) consequently, the CSA preempts the MUUMA as applied here. View "Bourgoin v. Twin Rivers Paper Co., LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court concluding that Appellant did not have standing to pursue a claim for visitation rights with her grandchild pursuant to the Grandparents Visitation Act (GVA), Me. Rev. Stat. 19-A, 1801-1805.Appellant, the grandmother of the child at issue, filed a petition to establish grandparents’ rights pursuant to the GVA, seeking specific rights of visitation and/or primary physical residence of the child. The district court concluded that Appellant had not established standing because she failed to make a prima facie showing of de facto parentage as required under the GVA to proceed on her petition. On appeal, Appellant argued, inter alia, that the court erred in finding that she did not have standing to proceed as a putative de facto parent. The Supreme Judicial Court affirmed, holding that Appellant did not establish standing to proceed to a hearing on her petition pursuant to the GVA or the statutory requirements of a de facto parenthood claim. View "Lamkin v. Lamkin" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Parents’ parental rights to their three children while also approving a permanency guardianship as a possible permanency plan.After Parents’ parental rights were terminated, they appealed. Parents did not contest the district court’s determination that they were unfit as the children’s parents but argued that the court erred by determining that termination was in the children’s best interests because the court also ordered a permanency plan that included either adoption or a permanency guardianship. In affirming, the Supreme Judicial Court held that, under the circumstances of this case, termination of Parents’ parental rights was not inconsistent with a permanency guardianship. View "In re Children of Nicole M." on Justia Law