Justia Maine Supreme Court Opinion Summaries

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 the evidence supported the district court’s finding of parental unfitness. Specifically, the Court held that the district court’s findings that Father was unwilling or unable to protect the child from jeopardy within a time reasonably calculated to meet the child’s needs and failed to make a good faith effort to rehabilitate and reunify with him were based on competent evidence in the record. Therefore, the court did not err in its determination of unfitness. View "In re Child of Daniel Q." on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court entering summary judgment in favor of Curtis Frye, Daryl Frye, and the Estate of Carroll Frye (collectively, the Estate) on the Estate’s action seeking enforcement of a property insurance contract for the loss of a dwelling by fire. The Court held that the trial court erred by interpreting Carroll’s insurance contract with MMG Insurance Company as providing coverage to the Estate because when the fire occurred, several weeks after Carroll’s death, none of the parties was both insured by MMG and in possession of an insurable interest. Therefore, Me. Rev. Stat. 24-A, 2406 preluded enforcement of the policy as to the dwelling as a matter of law. The Court remanded the case for entry of a summary judgment in favor of MMG. View "Estate of Carroll G. Frye v. MMG Insurance Co." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(b) and (B)(2)(a), (b)(i)-(ii). The Court held (1) the district court did not err by invoking the “rebuttable presumption” contained in Me. Rev. Stat. 22, 4055(1-A)(A), (B)(8) in its unfitness analysis because the evidence in its entirety supported a finding of unfitness; and (2) there was sufficient evidence in the record to support the court’s finding that termination of Father’s parental rights was in the child’s best interest. View "In re Child of Gustavus E." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder. The Court held (1) the trial court did not abuse its discretion or commit obvious error when it excluded evidence that the State of Maine’s Chief Medical Examiner had been removed from his former position as Chief Medical Examiner for the Commonwealth of Massachusetts; and (2) the trial court did not err, much less commit obvious error, when it instructed the jury on how it could evaluate evidence of flight to avoid prosecution. View "State v. Haji-Hassan" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for three counts of murder and one count of gross sexual assault and the sentences of life imprisonment imposed on each of the murder counts. The Court held (1) the trial court abused its discretion by foreclosing Defendant’s cross-examination of the State’s Chief Medical Examiner concerning his termination from his position as the Chief Medical Examiner in Massachusetts, but the error was harmless; (2) the trial court did not clearly err by finding that the State had sufficiently established the chain of custody of the sexual assault kit used during the autopsy of one of the victims; (3) there was sufficient evidence to support the jury’s guilty verdict on the gross sexual assault charge; (4) the State did not commit prosecutorial misconduct in its opening statement; and (5) the trial court applied a correct standard of proof and did not abuse its discretion in determining the facts considered at sentencing. View "State v. Coleman" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of arson. On appeal, Defendant argued that the trial court violated his right to be protected against double jeopardy by admitting in his trial evidence on which the State relied to try to prove some of the charges of which Defendant was acquitted in a prior trial. The Supreme Judicial Court agreed, holding that the admission of that evidence was barred by collateral estoppel and violated Defendant’s right to be protected from double jeopardy and that the error was not harmless. View "State v. Weckerly" on Justia Law

The Supreme Judicial Court affirmed the trial court’s judgment convicting Defendant of three counts of possession of sexually explicit material, thus denying Defendant’s challenges to the denial of his motion to suppress statements and digital evidence obtained by the police after they entered his home. On appeal, Defendant argued that the trial court erred in finding that he consented to the police officers’ entry into his home, which resulted in the search and seizure of his computer. The Supreme Judicial Court held that there was sufficient evidence in the record to support a finding that Defendant consented to the officers’ entry. View "State v. Marquis" on Justia Law

In this criminal case, the Supreme Court dismissed Defendant’s appeal from the dismissal of his motion to vacate as moot and remanded the case for further proceedings.While Defendant’s competency to stand trial was under consideration and his motion to dismiss the charges on the basis of prosecutorial misconduct was pending, the trial court held an ex parte conference with the prosecutor to discuss the alleged prosecutorial misconduct. Defense counsel was not notified of the conference and did not consent to the ex parte communication. The same jurist later found Defendant competent to stand trial, denied Defendant's motion to dismiss, and denied Defendant’s motions to suppress. Defendant then entered a conditional guilty plea. While Defendant’s appeal remained pending, the Supreme Court authorized additional proceedings in the trial court so Defendant could obtain the transcript of the ex parte conference. Defendant then filed a motion to vacate the judgment of conviction and motion for the jurist’s recusal. The jurist recused himself. The court then dismissed Defendant’s motion to vacate. On appeal, the Supreme Court vacated all adjudicatory action undertaken after the ex parte conference and dismissed Defendant’s appeal form the dismissal of the motion to vacate as moot. View "State v. Bard" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated trafficking in scheduled drugs, unlawful possession of a scheduled drug, and unlawful possession of oxycodone. On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence that was found in the curtilage of his home and abused its discretion in denying his motion to exclude other evidence on the basis of a discovery violation. The Supreme Court disagreed, holding (1) the evidence obtained as a result of law enforcement officers’ search of bags they discovered within Defendant’s “curtilage” was properly admitted under the plain view exception and the inevitable discovery exception to the warrant requirement; and (2) the court did not err in denying Defendant’s motion to exclude the testimony of a pharmacist because the State had only recently notified Defendant that the pharmacist would testify in the place of another pharmacist who had also been on the witness list. View "State v. Sullivan" 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), (ii), (iv). The Court held (1) the district court’s findings were sufficient to support the court’s conclusion that Father was unable to protect his child from jeopardy, was unable to take responsibility for the child within a time reasonably calculated to meet the child’s needs, and did not make a good faith effort to rehabilitate and reunify with the child; and (2) the district court did not abuse its discretion by concluding that termination of Father’s parental rights was in the best interest of the child. View "In re Child of Nuradin A." on Justia Law