Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of hindering apprehension, obstructing government administration, and refusing to submit to arrest. On appeal, Defendant argued that the trial court’s jury instructions on the justification of defense of premises were deficient. The Supreme Judicial Court disagreed, holding (1) a citizen is not justified in using nondeadly force against a law enforcement officer for the purpose of defending one’s premises; and (2) because the Criminal Code does not create a justification that allowed Defendant to use nondeadly force against the law enforcement officer in this case in order to defend her premises, Defendant was not entitled to any instruction on that issue. View "State v. French" on Justia Law

The Department of Health and Human Services initiated a child protection proceeding. The court entered a preliminary protection order and placed Corey in Department custody on April 22, 2017, the day the child was born. After a contested hearing the district court entered a jeopardy order with respect to Corey, including a provision, based on the court’s finding that continued reunification services were inconsistent with the permanence plan, relieving the Department of its obligation to provide Corey’s mother with reunification services under 22 M.R.S. 4041(2)(A-2)(2). The court made findings that the mother has been diagnosed with Schizoaffective Disorder and struggles with daily functioning and social interactions. According to her psychiatric nurse practitioner, the mother can do no more than manage her own activities of daily living; she has been living at a homeless shelter for seven years and cannot live there with a child, nor could she live in a group home with a child. The Maine Supreme Judicial Court affirmed, finding that the determination of jeopardy was supported by the evidence. View "In re Corey T." on Justia Law

At issue was the application of the consent to adoption statute, Me. Rev. Stat. 18-A, 9-302, to contested adoption proceedings heard in the district court following a district court judgment terminating parental rights concerning the child.The Supreme Judicial Court affirmed the judgment of the trial court finding that Foster Parents had met their burden to prove by a preponderance of the evidence that the Department of Health and Human Services had acted unreasonably in withholding its consent to their adoption of Child. Because Child’s parents’ rights had been terminated and because the Department had legal custody of Child, section 9-302(a)(3) required that the Department’s written consent had to be obtained before any adoption could be granted. After a hearing, the district court found that the Department unreasonably withheld its consent to Foster Parents’ adoption petition. The Supreme Judicial Court affirmed, holding that the evidence in the record supported the trial court’s findings and discretionary determinations. View "In re Adoption of Paisley" on Justia Law

The Supreme Court concluded that former York County Probate Judge Robert M.A. Nadeau violated Rule 2.11(A) of the Maine Code of Judicial Conduct when he participated in the resolution of a case after acknowledging that he would be required to recuse for bias if an evidentiary hearing were necessary. The court accepted the Committee on Judicial Responsibility and Disability’s recommendation and ordered that Judge Nadeau be publicly reprimanded for violating Rule 2.11(A), noting that, while a sanction was warranted for Judge Nadeau’s misconduct, the need to deter others from similar misconduct was tempered by the fact that Judge Nadeau was no longer a judicial officer and was serving a suspension from the practice of law. View "In re Robert M.A. Nadeau" on Justia Law

Me. Rev. Stat. 17-A, 1112 is facially constitutional, and, in the instant case, the trial court’s admission of a lab certificate in lieu of live witness testimony pursuant to that statute was not a violation of Defendant’s right of confrontation.Defendant appealed from a judgment, entered after a jury trial, convicting her of unlawful trafficking of a schedule W drug. At issue was whether the trial court’s admission of a lab certificate identifying a substance exchanged in a controlled purchase as methamphetamine. The court admitted the lab certificate in lieu of the testimony of the chemist pursuant to section 1112. The Supreme Court affirmed, holding (1) section 1112 is facially constitutional; (2) Defendant’s failure to timely demand a live witness pursuant to section 1112 effected a voluntary, knowing, and intentional waiver of her Confrontation Clause rights; and (3) therefore, the trial court did not err in allowing into admission the chemist’s certificate in lieu of live testimony. View "State v. Jones" on Justia Law

The motion court did not err by applying the inevitable discovery doctrine to deny Defendant's motion to suppress evidence of drugs found on his person before the issuance of a search warrant.The Unified Criminal Docket found Defendant guilty of unlawful trafficking in scheduled drugs and ordering a criminal forfeiture. In denying Defendant’s motion to suppress drug evidence, the trial court found that law enforcement officers’ warrantless entry into an apartment was not justified by exigent circumstances but that it was highly likely that the officers inevitably would have discovered drugs. The Supreme Court affirmed the denial of the motion to suppress, holding (1) the motion court did not err by finding that the police inevitably would have discovered the drug evidence at issue by lawful means; and (2) application of the inevitable discovery doctrine does not create an incentive for police misconduct and does not significantly weaken Fourth Amendment protections. View "State v. Prinkleton" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of possession of sexually explicit material depicting a minor under twelve years old and the sentence imposed in connection with the conviction. The court imposed a sentence of three years’ incarceration and two years of probation with certain conditions, including a restriction against unsupervised contact with children under the age of sixteen years. Defendant appealed, challenging the denial of his motion to suppress his statements to the police and the condition of his probation permitting him only supervised contact with his infant son. The Supreme Court held (1) the admission of Defendant’s confession was fundamentally fair; and (2) the “no unsupervised contact” provision of Defendant’s probation was within the court’s authority and did not violate Defendant’s constitutional rights. View "State v. Annis" 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)(a) and (B)(2)(a), (b)(i)-(ii), (iv). On appeal, Father argued that the district court erred by finding that he was unfit as a parent and abused its discretion by determining that termination of his parental rights was in the child’s best interest. The Supreme Judicial Court held (1) the district court’s findings that Father was unfit as a parent had support from competent evidence in the record; and (2) the district court did not abuse its discretion in determining that termination of Father’s parental rights was in the child’s best interest. View "In re James C." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Parents’ parental rights to their child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii). On appeal, Parents challenged the sufficiency of the evidence supporting the district court’s finding of parental unfitness and the court’s discretionary determination that termination was in the best interest of the child. In addition, Father argued that the Department did not meet its obligation to provide reunification services. The Supreme Judicial Court held that the district court did not err or abuse its discretion in determining that termination of Parents’ parental rights, with a permanency plan for adoption, was in the child’s best interest. View "In re Emma S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2). On appeal, counsel for Mother filed an appellate brief containing a statement that counsel believed there were no arguable issues of merit for an appeal. The Supreme Judicial Court held (1) the record supported the district court’s findings of parental unfitness as to Mother; and (2) there was sufficient evidence in the record to support the court’s findings and discretionary determination that termination of Mother’s parental rights was in the children’s best interests. View "In re Dante C." on Justia Law