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). On appeal, Father argued that the evidence was insufficient as to the finding of unfitness and challenged the district court’s finding and discretionary determination that termination was in the child’s best interest. The Supreme Judicial Court held (1) the evidence was sufficient to support the court’s unfitness findings; and (2) the evidence was sufficient to support a finding that termination was in the child’s best interest. View "In re Emma C." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant’s motion for a new trial, which Defendant brought pursuant to the post-conviction DNA analysis statute, Me. Rev. Stat. 15, 2135-2138. The Supreme Judicial Court held that the district court did not err or abuse its discretion by (1) finding that Defendant failed to show by clear and convincing evidence that new DNA evidence admitted at the hearing on Defendant’s motion made it probable that a different verdict would result upon a new trial; and (2) declining to consider evidence pointing to an alternative suspect upon finding that the proffered evidence was not relevant to the new DNA evidence. View "State v. Bates" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his two children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv). On appeal, Father argued that the guardian ad litem failed to satisfy his statutory obligations to conduct an in-person interview with Father and to notify Father’s attorney that Father was imprisoned before the cease reunification order went into effect. The Supreme Judicial Court disagreed, holding (1) Father’s argument regarding the notification of incarceration failed for several reasons; and (2) the court’s findings that Father was unfit and that termination was in the children’s best interests was not in error or an abuse of discretion. View "In re Aurora M." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court, entered after a jury trial, finding that Defendant had committed the civil violations of improperly displaying a registration plate and failing to register a vehicle that is operated or remains on a public way. Contrary to Defendant’s arguments on appeal, the Supreme Court held (1) the district court did not err in finding that the State established the elements of each violation; and (2) the court proceedings below did not violate the Due Process Clause, the Equal Protection Clause, or the Americans with Disabilities Act. View "State v. Chase" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Father and Mother to their children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii). On appeal, Mother challenged the sufficiency of the evidence to support the trial court’s finding of parental unfitness, and Father’s counsel filed a brief indicating that there were no arguable issues with merit in this appeal. The Supreme Judicial Court held (1) the district court did not err when it determined that Mother and Father are unfit pursuant to section 4055(1)(B)(2)(b); and (2) the district court did not err or abuse its discretion by determining that termination was in the children’s best interests. View "In re Meena H." 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)-(iii). On appeal, Father argued that the court impermissibly relied on his incarceration in finding parental unfitness and erred in its best interest determination. The Supreme Judicial Court disagreed, holding (1) Father’s arguments regarding his imprisonment failed in several respects; and (2) the court did not err or abuse its discretion by determining that termination of Father’s parental rights, with a permanency plan of adoption, was in the child’s best interest. View "In re Asanah S." on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his three children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii). On appeal, Father argued that the evidence did not support the court’s finding of parental unfitness and its discretionary determination that termination was in the children’s best interests. The Supreme Judicial Court disagreed, holding that the district court’s findings were supported by competent evidence in the record and that the court did not err in its determination of unfitness or in determining that termination of Father’s parental rights, with a permanency plan of adoption, was in the children’s best interests. View "In re Zarianna C." on Justia Law

The Supreme Judicial Court vacated the judgment entered by the superior court upholding the final agency decision of the Department of Health and Human Services denying Appellant’s application for food supplement benefits.The Department denied Appellant’s application for food benefits based on language in the public law not present within the statutory text. The language at issue contained a fiscal limitation of $261,384 and a temporal limitation - June 30, 2015 - on the availability of funding for benefits for persons otherwise eligible under Me. Rev. Stat. 22, 3104-A(1)(D) (Paragraph D). The Supreme Judicial Court concluded that the Legislature intended for Paragraph D to be a permanent exception to the general ineligibility of noncitizen for food assistance under section 3104-(A)(1) and that the temporal and fiscal limitations contained in P.L 2013, ch. 368, section 00-14 applied only to the fiscal years ending June 30, 2013, June 30-2015, and June 30, 2015 and not beyond June 30, 2015. View "Manirakiza v. Department of Health & Human Services" on Justia Law

The Supreme Judicial Court affirmed the judgment of the juvenile court adjudicating Appellant of the juvenile crime of gross sexual assault. On appeal, Appellant argued that the evidence was insufficient to support the adjudication, that the court deprived him of due process when it denied his motion for production of Department of Health and Human Services records without conducting an in camera review, and that the investigative and adjudicatory processes and the outcome of the case did not comport with the policies of the Juvenile Code. The Supreme Judicial Court disagreed and summarily disposed of Appellant’s essential challenges on appeal. In addition, the court noted that the Legislature may wish to review Me. Rev. Stat. 17-A, 253(1)(C) to consider how the statute “is most effectively and appropriately applied in juvenile cases to achieve the purposes of the Juvenile Code.” View "State v. Fulton" on Justia Law

The probate court did not err in adopting the report of a referee and imposing a constructive trust on Plaintiff’s interests in real property, but remand is necessary for the probate court to enter an appropriate judgment.Plaintiff, individually and as personal representative of the Estate of Stephen E. Libby, filed a complaint against her brother. Plaintiff’s brother filed a counterclaim against Plaintiff. A referee concluded that Plaintiff committed constructive fraud and recommended the imposition of a constructive trust on certain real estate. The probate court adopted the referee’s report and ordered judgment “entered in the record.” The Supreme Court affirmed, holding (1) the probate court did not err in adopting the referee’s report; but (2) the court’s docket entry did not comply with rules 58 and 79 of the Maine Rules of Probate Procedure regarding the entry of judgment. The court remanded with directions that the probate court enter an appropriate judgment. View "In re Estate of Stephen E. Libby" on Justia Law