Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment entered by the district court denying Father’s Me. R. Civ. P. 60(b) motion for relief from judgment after the court granted Mother’s motion to modify a parental rights and responsibilities order regarding the parties’ son. On appeal, Father argued that the court erred in denying his motion because (1) after another state assumed jurisdiction over the child custody matter, Maine necessarily lost jurisdiction over that matter; and (2) the court erred by not allowing him to present facts and legal arguments to the court before a decision on jurisdiction was made. The Supreme Judicial Court disagreed, holding (1) Maine maintained exclusive, continuing jurisdiction over the child custody matter pursuant to Me. Rev. Stat. 19-A, 1746(1); and (2) the court acted within the confines of section 1740(2), and because Father on two occasions had already presented facts and legal arguments regarding jurisdiction, the court did not abuse its discretion in denying Father a third opportunity to address the matter. View "Fitzpatrick v. McCrary" on Justia Law

The Supreme Judicial Court vacated the judgment of foreclosure entered by the superior court in favor of Deutsche Bank National Trust Company, holding that the superior court abused its discretion by admitting into evidence a copy of a notice of default that contained an assertion that it was sent by mail.In answer to a complaint for foreclosure filed by Deutsche Bank, Jesse and Naomi Eddins asserted that the Bank failed to comply with the notice provisions of Me. Rev. Stat. 14, 6111. The matter proceeded to trial. On appeal, the Supreme Judicial Court remanded the matter for entry of judgment for the Eddinses, holding that Deutsche Bank presented no competent evidence that a notice of default was sent to Jesse or that any such notice met the requirements of either section 6111 or the mortgage instrument itself. Therefore, the Bank failed as a matter of law to prove a necessary element of its foreclosure claim, and the Eddinses were entitled to judgment. View "Deutsche Bank National Trust Company v. Eddins" on Justia Law

The Supreme Judicial Court vacated the judgment of foreclosure entered by the superior court in favor of Deutsche Bank National Trust Company, holding that the superior court abused its discretion by admitting into evidence a copy of a notice of default that contained an assertion that it was sent by mail.In answer to a complaint for foreclosure filed by Deutsche Bank, Jesse and Naomi Eddins asserted that the Bank failed to comply with the notice provisions of Me. Rev. Stat. 14, 6111. The matter proceeded to trial. On appeal, the Supreme Judicial Court remanded the matter for entry of judgment for the Eddinses, holding that Deutsche Bank presented no competent evidence that a notice of default was sent to Jesse or that any such notice met the requirements of either section 6111 or the mortgage instrument itself. Therefore, the Bank failed as a matter of law to prove a necessary element of its foreclosure claim, and the Eddinses were entitled to judgment. View "Deutsche Bank National Trust Company v. Eddins" on Justia Law

The evidence presented to the Secretary of State’s hearing examiner supported the determination that Walter Melevsky III failed to submit to a test of his blood-alcohol concentration, and therefore, the hearing examiner properly denied Melevsky’s petition to rescind the administrative suspension of his driver’s license.The superior court vacated the hearing examiner’s decision and ordered the Secretary of State to reinstate Melevsky’s driver’s license, concluding that the Secretary’s decision was erroneous as a matter of law. The Supreme Judicial Court disagreed, holding that the hearing examiner’s determination that Melevsky failed to submit to a test of his blood-alcohol level was supported by substantial evidence. View "Melevsky v. Secretary of State" 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 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