Justia Maine Supreme Court Opinion Summaries

The Supreme Court vacated the child support order and the associated part of the divorce judgment in this case and remanded to the trial court for clarification because the child support order and the judgment were inconsistent with each other and there was an error in the court’s establishment of Father’s monthly child support obligation.Father filed a motion to modify the parties’ amended divorce judgment. The district court granted Father’s motion to modify and modified his schedule of contact with the parties’ child and his child support obligation. The Supreme Court vacated the child support order and provisions of judgment governing child support, holding that the inconsistency in the child support order and the judgment, combined with the unsupported determination that Father must pay $200 per month in child support, made effective appellate review impossible. View "Papadopoulos v. Phillips" on Justia Law

The Supreme Judicial Court dismissed this interlocutory appeal brought by Defendants challenging the superior court’s denial of their motion to seal or strike, holding that Defendants did not demonstrate the irreparable harm necessary for appellate review of the court’s interlocutory order.Plaintiff, the respondent in an attorney discipline proceeding, filed a complaint against Judge Marian Woodman and Judge Nancy Carlson based on their actions and involvement in the disciplinary proceeding. Defendants filed motions to dismiss the complaint and sought imposition of sanctions. After Plaintiff filed a response to the motions the judges filed a motion to seal or strike certain paragraphs of Plaintiff’s response, in which Plaintiff made assertions about the judges and a family member of one of them. The superior court denied the motion. The judges appealed. The Supreme Judicial Court dismissed the appeal, holding that the appeal did not fall within an exception to the final judgment rule. View "Carey v. Maine Board of Overseers of the Bar" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court dismissing Appellant’s complaint seeking to be determined a de facto parent of her grandson. The district court concluded, after a contested hearing, that Appellant failed to establish that she had standing to proceed to a plenary hearing. Specifically, the court found that Appellant did not present prima facie evidence that the child resided with her for a significant period of time or that the mother regarded Appellant as a parent to the child. The court further concluded that the best interest of the child was insufficient to confer standing on Appellant. The Supreme Judicial Court agreed, holding (1) the court was required to dismiss the complaint because Appellant did not have standing to proceed with her de facto parenthood claim; and (2) the court did not hold Appellant to a greater standard than that to which an unrelated third party would be held. View "Davis v. McGuire" 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. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv), holding that Father failed to present a prima facie case of ineffective assistance of counsel and that the record evidence supported the court’s findings and discretionary determinations.On appeal, Father argued that his counsel’s withdrawal two months before the termination hearing amounted to ineffective assistance of counsel. The Supreme Judicial Court disagreed, holding that Father did not demonstrate prejudice from counsel’s performance. View "In re Child of Stephen E." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of assault, holding that Defendant was not denied a fair trial because one of the jurors reported that she had felt pressured to return a guilty verdict.After the court informed the parties of the juror’s statement and invited the parties to be heard, the court concluded that there was no evidence of juror misconduct and that the guilty verdict would stand. The Supreme Judicial Court held that Defendant was not deprived of a fair trial because there was no evidence of outside influence, bias, or misconduct, and therefore, the juror’s statement that she felt pressured to return a guilty verdict fell within the categories of evidence prohibited from use by Me. R. Evid. 606(b)(1). View "State v. Leon" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Appellant’s petition for release and discharge from the custody of the Commissioner of Health and Human Services pursuant to Me. Rev. Stat. 15, 104-A. The Court held that, contrary to Appellant’s argument on appeal, the superior court applied the correct standard when it denied Appellant’s petition for release and discharge and properly denied the petition where Appellant failed to prove that he “may be released or discharged without likelihood that [he] will cause injury to [himself] or to others due to a mental disease or mental defect.” View "Begin v. State" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court affirming in part the decision of the Department of Agriculture, Conservation and Forestry (DACF) to deny portions of Appellants’ request for records pursuant to the Freedom of Access Act (FOAA).The records at issue were a series of drafts of a letter that DACF sent to representatives and entities associated with Dubois Livestock Inc. and portions of emails that identified people who made complaints against Dubois Livestock. In denying those portions of the FOAA request, DACF asserted that the material contained privileged information and work product and therefore was not subject to disclosure. The court concluded that DACF had properly withheld most of the material at issue. The Supreme Judicial Court affirmed, holding that the court did not err by declining to order production of records that DACF claimed were within the confidential informant identity privilege and therefore not subject to disclosure. View "Dubois v. Department of Agriculture, Conservation & Forestry" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part an order of the superior court upholding in part a decision of the Maine Office of the Attorney General (OAG) denying Dubois Livestock, Inc.’s Freedom of Access Act (FOAA) request for certain information related to an enforcement action filed against Dubois Livestock.Specifically, Dubois Livestock sought drafts of a letter sent by the Maine Department of Agriculture, Conservation and Forestry (DACF) to Dubois Livestock and a series of emails preparatory to a meeting held among agents of several state agencies in connection with the enforcement efforts. The OAG denied the FOAA request in its entirety. The superior court affirmed as to the drafts of the DACF letter, concluding that they were protected as work product, but reversed as to the emails, concluding that the emails were not privileged. The Supreme Court affirmed as to the draft letters but vacated the judgment as to the emails, holding that all of the documents in this case were protected work product material and not subject to disclosure pursuant to FOAA. View "Dubois v. Office of the Attorney General" on Justia Law

The Supreme Judicial Court vacated the judgment entered by the probate court granting the petition of Ella’s maternal grandmother for temporary guardianship, holding that the evidence did not support the court’s finding of a “temporarily intolerable” living situation for Ella.The probate court’s finding that a temporarily intolerable situated existed as to Ella living with her mother, Nicole, rested on its finding that Nicole’s home was not appropriate due to the limited amount of time she had been there and the existence of at least one pit bull dog, as well as Nicole’s testimony that she intended to stay at that home. The Supreme Judicial court held that these reasons were insufficient, as a matter of law, to justify an intrusion into Nicole’s fundamental liberty interest in the care, custody, and control of her child. View "In re Guardianship of Ella M. Grenier" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of aggravated assault.Defendant, a mixed martial arts fighter, repeatedly punched the victim in the head, rendering the victim unconscious. A jury found him guilty of aggravated assault. On appeal, Defendant argued that there was insufficient evidence to support his conviction and that there was insufficient evidence supporting a finding that the State disproved self-defense. The Supreme Court disagreed, holding that the State presented sufficient evidence to prove that Defendant manifested an extreme indifference to the value of human life and to disprove Defendant’s self-defense justification beyond a reasonable doubt. View "State v. Matthews" on Justia Law