Justia Maine Supreme Court Opinion Summaries

Pamela Gleichman, a real estate developer, established four affordable housing developments in Pennsylvania as limited partnerships in the 1990s. Gleichman and her company, Gleichman & Co., Inc., served as the general partners, while Metropolitan and U.S.A. Institutional held limited partnership interests. In 2014, Gleichman’s daughter, Rosa Scarcelli, acquired Gleichman & Co. (renamed General Holdings, Inc.) through a foreclosure auction. In 2018, Metropolitan and U.S.A. Institutional transferred their limited partnership interests to Eight Penn Partners, L.P., without the consent of General Holdings.General Holdings and Preservation Holdings filed a complaint in the Superior Court against Eight Penn, Metropolitan, and U.S.A. Institutional, seeking a declaratory judgment and injunctive relief. The case was transferred to the Business and Consumer Docket. The court denied Eight Penn’s motion for summary judgment, finding ambiguity in the partnership agreements regarding General Holdings’ status as a general partner. After a trial, the court ruled in favor of the plaintiffs, declaring that General Holdings remained a general partner with management rights and that the transfer of interests to Eight Penn was invalid without General Holdings’ consent.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court’s judgment. The court found that the partnership agreements required the consent of both general partners for a valid transfer of limited partner interests. The court concluded that the transfer of General Holdings’ controlling interest at a foreclosure auction did not require the limited partners’ consent. Therefore, General Holdings remained a general partner with management rights, and the transfer to Eight Penn was invalid. The court upheld the declaratory judgment and denied injunctive relief as unnecessary. View "General Holdings, Inc. v. Eight Penn Partners, L.P." on Justia Law

Charles R. Maples and Kathy S. Brown, owners of two condominium units, obtained a judgment against Compass Harbor Village Condominium Association and Compass Harbor Village, LLC for damages due to mismanagement. The judgment awarded Maples $134,900 and Brown $106,801, along with specific performance, declaratory relief, and attorney fees. The judgment prohibited the defendants from imposing special assessments to pay for the judgment. The judgment was affirmed in part by the Maine Supreme Judicial Court, but specific performance and the Unfair Trade Practices Act claim were vacated.Maples and Brown recorded writs of execution, obtaining liens against the LLC's and Association's properties. However, the LLC's units were foreclosed by The First, N.A., extinguishing the liens. Maples and Brown then filed a new action in the Superior Court, seeking to enforce the judgment against the remaining seven units not owned by them or foreclosed upon. The case was transferred to the Business and Consumer Docket, where the court dismissed their claims.The Maine Supreme Judicial Court reviewed the case and focused on whether the lower court erred in dismissing the claim to enforce the judgment lien against the seven units under the Maine Condominium Act, 33 M.R.S. § 1603-117. The court held that the proper procedure for enforcing such a lien requires a disclosure proceeding in the District Court, which has exclusive jurisdiction over such matters. The transfer to the Business and Consumer Docket did not cure the jurisdictional issue. Consequently, the court affirmed the dismissal of Maples and Brown’s claims, as the Superior Court and the Business and Consumer Docket lacked jurisdiction to issue the necessary turnover or sale orders under the disclosure statutes. View "Maples v. Compass Harbor Village Condominium Association" on Justia Law

Calixte Fleury was convicted of aggravated trafficking, unlawful trafficking, unlawful possession of scheduled drugs, and operating under the influence. On September 18, 2020, Fleury was driving on I-95 when he crashed his vehicle. A responding sergeant found Fleury with a bag of pills containing fentanyl and tramadol, and later discovered more fentanyl and cash on Fleury. Fleury's blood alcohol content was 0.093 grams per 100 milliliters. He was indicted and later charged with multiple counts, including aggravated trafficking and unlawful trafficking of scheduled drugs.The trial court (York County, Martemucci, J.) held a jury trial, resulting in guilty verdicts on all four criminal counts. The court found in favor of Fleury on the criminal forfeiture count. Fleury was sentenced to seven years with all but four years suspended for aggravated trafficking, three years for unlawful trafficking, and 30 days for operating under the influence, with some sentences running concurrently. The court merged the unlawful possession count with the unlawful trafficking count.The Maine Supreme Judicial Court reviewed the case. Fleury argued that the application of a repealed definition of "traffick" was unconstitutional. The court disagreed, stating that the repealed statute was rationally related to controlling opioids and its application was not unconstitutional. The court also noted that the amended statute did not apply retroactively to Fleury's case.However, the court found that the trial court should have merged the aggravated trafficking count with the unlawful trafficking and possession counts for sentencing. The Maine Supreme Judicial Court vacated the sentence and remanded for resentencing, affirming the convictions in all other respects. View "State of Maine v. Fleury" on Justia Law

Kulmiye Idris was convicted of gross sexual assault after a jury trial in Androscoggin County. The incident occurred on April 2, 2022, when Idris and the victim, who were close friends, attended a party. The victim consumed approximately twelve drinks and went to bed at a friend's house. She later woke up to Idris engaging in vaginal intercourse with her and told him to stop, but he did not stop until he was finished. The next morning, the victim confronted Idris via text, and he apologized, stating he did not remember the incident. The victim reported the assault to the police and underwent a forensic examination, which confirmed the presence of Idris's DNA.The Androscoggin County Grand Jury indicted Idris on one count of gross sexual assault. Idris pleaded not guilty, but after a two-day trial, the jury found him guilty. The court sentenced him to eight years in prison, with all but four years suspended, and four years of probation. Idris appealed, arguing that the trial court erred in its jury instructions regarding the mens rea requirement for the offense.The Maine Supreme Judicial Court reviewed the case and determined that the trial court's instruction to the jury to use a "recklessly" standard for the mens rea was not prejudicial, even though the correct standard should have been "criminal negligence." The court found that the jury's verdict would have been the same under the correct standard, as there was sufficient evidence to support the conviction. The court affirmed the judgment and called upon the Legislature to clarify the mens rea requirements for offenses under section 253. View "State of Maine v. Idris" on Justia Law

Christian D., the father of a three-year-old child, appealed a judgment by the District Court (South Paris) that terminated his parental rights. The court found him unfit as a parent and determined that termination was in the child's best interest. The father argued that the court abused its discretion by not making specific findings of fact to support its decision and by not adequately considering a permanency guardianship as an alternative to termination.The District Court found that the father was unfit based on three grounds under 22 M.R.S. § 4055(1)(B)(2)(b)(i), (ii), and (iv). The court noted that the child had been in the custody of the Department of Health and Human Services (DHHS) for 26 of his 35 months and that the child needed permanency, which the father could not provide in a timely manner. The child had been living in a stable and nurturing foster home with his maternal grandparents, who were willing to adopt him.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's judgment. The court held that the District Court properly exercised its discretion and that the record supported the findings that termination of the father's parental rights and adoption were in the child's best interest. The court also rejected the father's argument that Rule 52(a) precluded reliance on inferences or implicit findings, noting that the trial court's findings were sufficient to support the judgment. The court emphasized the importance of permanency for the child and found that the father's inability to provide a stable environment justified the termination of his parental rights. View "In re Child of Christian D." on Justia Law

Michael Zani and Peter Zani, sons of Patricia M. Spofford, appealed a summary judgment from the Lincoln County Probate Court. The court found no genuine issue of material fact regarding Spofford’s testamentary capacity when she executed her will on March 1, 2018. The Zanis argued that there was a genuine issue concerning her testamentary capacity, despite having no direct evidence from the date the will was executed. They contended that other evidence from before and after the will's execution cast doubt on her capacity.The Probate Court granted summary judgment, concluding that Spofford had the requisite testamentary capacity. The court relied on videos of the will’s execution, which showed Spofford understood the nature of her actions, knew the extent of her estate, identified her family members, and expressed clear wishes about her estate's disposition. Additionally, affidavits from Spofford’s attorney and a witness, as well as testimony from her primary care physician, supported the conclusion that she was competent on the day she executed her will.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Probate Court’s judgment. The court found that the evidence presented by the Zanis, including incidents and medical notes from before and after the will's execution, was too remote to create a genuine dispute of material fact regarding Spofford’s testamentary capacity on March 1, 2018. The court also noted that a diagnosis of dementia or Alzheimer’s disease does not preclude testamentary capacity and that being under guardianship or conservatorship does not automatically negate the ability to execute a will. The judgment of the Probate Court was affirmed. View "Estate of Spofford" on Justia Law

Keara M. Bernier was convicted of aggravated assault after a jury trial in Aroostook County. The incident occurred on June 6, 2022, when Bernier struck the victim, her partner, in the head with an aluminum baseball bat during an argument at their shared home. The victim did not seek medical attention immediately but reported the incident to the police the next day. Bernier was indicted in July 2022 and, after a jury trial in September 2023, was found guilty and sentenced to seven years in prison, with all but six months suspended, and three years of probation.At trial, Bernier argued that the trial judge's comments during her testimony questioned her veracity, thus denying her a fair trial. She also contended that the court erred in its jury instructions regarding the use of deadly force in self-defense, specifically that it failed to instruct the jury that she had no duty to retreat if she was in her dwelling place and was not the initial aggressor.The Maine Supreme Judicial Court reviewed the case. The court found no obvious error in the trial judge's comments, determining that the judge's instructions to Bernier to answer questions truthfully were aimed at keeping her focused and were not indicative of bias. However, the court agreed with Bernier that the jury instructions on the use of deadly force were incomplete. The instructions failed to include the statutory exception that Bernier had no duty to retreat if she was in her dwelling place and was not the initial aggressor.The Maine Supreme Judicial Court vacated Bernier's conviction and remanded the case for a new trial, holding that the omission of the dwelling-place exception in the jury instructions constituted an obvious error affecting Bernier's substantial rights. View "State of Maine v. Bernier" on Justia Law

Charles S. Keegan filed a complaint against the Estate of Phyllis C. Bradbury and its representatives, as well as Craig J. and Melissa M. Holmes, alleging that he had a right of first refusal to purchase a property at 1 Lower High Street in Eastport. Keegan based his claim on a purchase and sale agreement for a different property, which he argued included a provision granting him this right. The agreement's Section 26 stated that the buyer "would like the Right of First Refusal on the sale of abutting lot if ever sold."The Superior Court of Washington County dismissed Keegan's complaint for failure to state a claim upon which relief could be granted. The court found that the language in Section 26 was precatory and did not create an enforceable right of first refusal. Keegan's initial appeal was dismissed as interlocutory. Subsequently, the Holmeses filed a motion to dismiss, which the Superior Court granted, relying on the previous dismissal as the law of the case. This resulted in a final judgment against Keegan, who then appealed.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Superior Court's judgment. The court held that the language in Section 26 of the purchase and sale agreement was clear and did not create an enforceable right of first refusal. The phrase "would like" was deemed precatory, expressing a wish rather than a binding obligation. Consequently, Keegan's complaint failed to state a claim upon which relief could be granted, as there was no enforceable right of first refusal, no breach of contract, and no basis for rescission or equitable relief. View "Keegan v. Estate of Bradfury" on Justia Law

Aubrey Armstrong was convicted of felony murder and robbery following a bench trial in July 2018. He was sentenced to thirty years for felony murder and a concurrent thirty-year term for robbery, with all but twenty-nine years suspended and four years of probation. Armstrong appealed, and the Maine Supreme Judicial Court found that his simultaneous convictions for felony murder and robbery violated the double jeopardy clause. The court vacated the judgment and remanded for further proceedings to merge the counts and impose a sentence on the merged count. On remand, the trial court dismissed the robbery count and resentenced Armstrong to thirty years for the merged count. Armstrong's subsequent appeals were denied.Armstrong filed his first petition for post-conviction review on April 10, 2023, which was summarily dismissed for failing to allege any cognizable grounds for relief. He then filed a second petition on June 29, 2023, alleging ineffective assistance of counsel and prosecutorial misconduct. The PCR court dismissed this petition as untimely, as it was filed beyond the one-year deadline. Armstrong appealed and sought a certificate of probable cause, which was granted by the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the case and concluded that Armstrong waived his argument regarding the timeliness of his petition by not raising it in the lower court. The court vacated the order granting a certificate of probable cause and dismissed the appeal as improvidently granted. The court did not address whether the doctrine of equitable tolling applies to petitions for post-conviction review, as Armstrong failed to present this argument to the PCR court. View "Armstrong v. State of Maine" on Justia Law

Alrig USA Acquisitions LLC, a commercial real estate developer, entered into a purchase and sale agreement with MBD Realty LLC for a property in Portland. MBD was aware that the City of Portland planned to redevelop the area, which would involve condemning part of the property, but did not disclose this to Alrig. The agreement included clauses allowing Alrig to terminate the agreement and receive a refund of its deposit under certain conditions, including eminent domain. Alrig extended the inspection period multiple times, paying additional deposits, and eventually waived its due diligence and title review contingencies, making the deposit nonrefundable except in the event of MBD’s default. Alrig later learned of the redevelopment plans and terminated the agreement, seeking a refund of the deposit, which MBD refused.The Superior Court (Cumberland County) granted MBD’s motion to dismiss Alrig’s complaint for breach of contract and fraud, concluding that MBD had no duty to disclose the redevelopment plans. Alrig appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the Superior Court’s judgment. The court held that the amendment to the agreement unambiguously made the deposit nonrefundable except in the event of MBD’s default, and thus Alrig’s contract claim failed. Additionally, the court found that MBD did not actively conceal the City’s planned condemnation, and there was no special relationship imposing a duty to disclose. Therefore, Alrig’s fraud claim also failed as a matter of law. The court concluded that Alrig was not entitled to relief under any set of facts that might be proven in support of its claims. View "Alrig USA Acquisitions LLC. v. MBD Realty LLC" on Justia Law