Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to two of her children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii), (iv).On appeal, Mother argued that the district court abused its discretion in proceeding with the termination hearing despite her request to replace her court-appointed counsel. Mother did not challenge the court’s findings of parental unfitness and that termination was in the children’s best interests. The Supreme Judicial Court held that, on the facts of this case, the trial court did not abuse its discretion in proceeding with the termination hearing. View "In re Children of Tasha R." on Justia Law

The Supreme Judicial Court vacated the judgment of the district court denying the maternal grandmother’s petition to adopt Parker J., granting the adoption to Parker’s paternal grandmother on her petition, and also granting adoption, despite the lack of a petition, to the paternal grandmother’s partner.This adoption proceeding followed the termination of the parental rights of Parker’s biological parents. The court denied the adoption petitions of the material grandmother and material grandfather and granted the adoption petition of the paternal grandmother while also granting an adoption to the partner of the paternal grandmother. The Supreme Court vacated the judgment because (1) the paternal grandmother’s partner did not petition for adoption and had no formal commitment to Parker or even to the paternal grandmother, and (2) the trial court considered and decided the matter treating the paternal grandmother and her partner as if they were joint petitioners. View "Adoption of Parker J." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her children, holding that the record supported the finding of parental unfitness. Specifically, the Court held (1) based on the facts found by the district court, all of which had evidentiary support, the court did not err finding that Mother remained unable to protect the children from jeopardy or take responsibility for them within a time that is reasonably calculated to meet their needs; and (2) the court did not err in determining that termination of Mother’s parental rights was in the children’s best interest. View "In re Children of Dani B." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her children, holding that the record supported the finding of parental unfitness. Specifically, the Court held (1) based on the facts found by the district court, all of which had evidentiary support, the court did not err finding that Mother remained unable to protect the children from jeopardy or take responsibility for them within a time that is reasonably calculated to meet their needs; and (2) the court did not err in determining that termination of Mother’s parental rights was in the children’s best interest. View "In re Children of Dani B." on Justia Law

The Supreme Judicial Court dismissed the appeal brought by Appellant challenging his sentence requiring him to pay $7,500 in restitution based on his involvement in damaging rental property from which he was evicted. The appeal was dismissed because Appellant did not properly assert that there was any illegality apparent on the record. Rather, Appellant challenged only the factual and discretionary determinations of the lower court. Because these are decisions that the Supreme Judicial Court does not review in a direct appeal of a sentence, the Court dismissed Appellant's appeal. View "State v. Plante" on Justia Law

The Supreme Judicial Court dismissed Appellant’s appeal from a judgment of conviction of manslaughter following Appellant’s unconditional open guilty plea, holding that Appellant provided no persuasive reason for the Court to depart from its longstanding jurisprudence strictly limiting direct appeal following a guilty plea.On appeal, Appellant argued that his plea was involuntary because he was coerced to accept the truth of all the facts recited by the State at the plea hearing and that he should not be required to show cause as to why his appeal should not be dismissed pursuant to State v. Huntley, 676 A.2d 501 (Me. 1996), and its progeny, which provide that a defendant may not appeal from a conviction entered upon his guilty plea except under certain circumstances. Because Appellant did not move to withdraw his unconditional plea before the court imposed the sentence and did not assert that the trial court lacked jurisdiction or that it imposed an excessive, cruel, or unusual sentence, this appeal must be dismissed. View "State v. Adams" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the sentencing court following Defendant’s guilty plea to an information charging him with felony murder. The sentencing court imposed a prison sentence of twenty years, all but ten years suspended, with four years’ probation and a restitution order. On appeal, Defendant argued that his sentence was unconstitutionally disproportionate and denied his constitutional right to equal protection. The Supreme Judicial Court disagreed, holding (1) Defendant’s offense and sentence did not generate an “inference of gross disproportionality”; and (2) notwithstanding the fact that Defendant’s codefendant received only a seven-year sentence, Defendant’s sentence did not violate Defendant’s equal protection rights. View "State v. Lopez" on Justia Law

The Supreme Judicial Court affirmed Defendant’s sentence entered in the Unified Criminal Docket following Defendant’s guilty plea to two counts of aggravated criminal operating under the influence and possession of a firearm by a prohibited person.On appeal, Defendant argued that, notwithstanding an agreement with the State that his sentence would not exceed an agreed upon “cap,” the sentencing court was required to explain its selection of the basic, maximum, and final periods of incarceration. In affirming, the Supreme Judicial Court held that any error in the court’s articulation of the sentence was not sufficiently prejudicial to affect the outcome of the proceeding and did not affect Defendant’s substantial rights. View "State v. Bean" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s and Father’s parental rights to their daughter pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i),(ii), and (iv). The Court held, contrary to the parents’ arguments on appeal, that (1) there was sufficient evidence to support the court’s findings of parental unfitness; and (2) the court did not commit obvious error when it determined that termination of Father’s parental rights, with a permanency plan of adoption, was in the child’s best interest. View "In re Child of Kelcie L." on Justia Law

The Supreme Judicial Court vacated the order of the trial court quashing Appellant’s subpoenas of mental health records of the alleged victim without first viewing the records in camera and remanded for the production and in camera review of some or all of the requested mental health records.Appellant was convicted of gross sexual assault of a person under the age of fourteen and unlawful sexual contact. On appeal, Appellant challenged the court’s decision to quash his subpoenas of the mental health records, the court’s denial of his motion to suppress statements made to law enforcement, and the court’s denial of his motion for a judgment of acquittal. The Supreme Court held (1) the trial court did not err in its rulings on either Appellant’s motion to suppress or his motion for a judgment of acquittal; but (2) because it was relatively certain that the records contained some evidence concerning the exact crimes charged, and the identity of the alleged perpetrator was directly at issue at trial, due process demanded that the court must proceed with an in camera review. View "State v. Olah" on Justia Law