Justia Constitutional Law Opinion Summaries

The town manager of the Town of Freeport signed a contract transferring the Town's emergency dispatch services to another town. Plaintiffs, two Town residents, filed an amended complaint requesting a declaratory judgment that the contract was void because it was inconsistent with section 6.10 of the Town's charter, which provides that multi-year contracts must be "made or approved by ordinance," and seeking an injunction. The Town Council later voted in favor of an ordinance that ratified the contract. The superior court subsequently dismissed the complaint, finding that the case was moot because the Town had approved the outsourcing contract by ordinance, thereby complying with section 6.10. The Supreme Court vacated the judgment and held (1) the court erred by dismissing the amended complaint because the passage of the ordinance ratifying the transfer of dispatch services contract did not render the case moot, as the contract did not conclude until the year 2016; but (2) the passage of the ordinance did satisfy the "made or approved by ordinance" requirement of section 6.10 of the charter. Remanded for entry of a judgment in favor of the Town on the merits of the amended complaint and denying the request for an injunction.

Chuck Starbird submitted an application for a building permit for the construction of a home on a lot abutting a public easement portion of a road in the Town of Minot. The Town denied the application. The Board of Appeals ultimately granted Starbird's appeal, concluding that the parcel had a private right-of-way because the the term "right-of-way," as used in section 4-501.8 of the Town's Land Use Code, included a public easement. The superior court affirmed but remanded to the Board for further factual findings on whether Starbird's application met all of the factors listed in section 4-501.8(A)-(G). The Supreme Court affirmed the superior court but vacated the portion of the court's judgment remanding the matter, holding (1) the unique circumstances of the matter caused the interlocutory appeal to fall within the judicial economy exception to the final judgment rule; and (2) the Board did not err by granting Starbird's appeal of the denial of his application.

The district court found that Michael Dee committed the civil violation of possessing a useable amount of marijuana. The Supreme Court affirmed. Dee subsequently filed a motion for reconsideration, arguing that Maine's prohibition against the possession of marijuana unconstitutionally infringed on his due process rights. The Court again affirmed, holding that the Legislature's prohibition met the rational basis standard, as (1) the statute provided for the public welfare because there was evidence that marijuana is harmful; (2) the legislative means employed were appropriate to achieve the ends sought; and (3) the manner of exercising the police power, by imposing a civil fine for the possession of marijuana, was not arbitrary or capricious.

Timothy Robbins entered a conditional plea of guilty to and was convicted of operating under the influence (OUI), with two prior convictions, and operating after suspension. Robbins appealed, contending that the trial court erred in denying his motion to strike two prior uncounseled misdemeanor OUI convictions, which reflected that he appeared pro se but were silent as to the procedures taken to ensure that his constitutional right to counsel was satisfied. The Supreme Court affirmed the judgment of conviction, holding that Robbins could not prevail on the record because, as no evidence was presented to the contrary, the Court presumed the regularity that attaches to the final judgment of a conviction.

Following a nonjury trial, James Soucy was convicted of operating a motor vehicle under the influence of intoxicants (OUI) with one previous OUI conviction within a ten-year period. Soucy appealed, arguing that the evidence of impairment from his use of prescription drugs was insufficient to convict him of OUI. The Supreme Court affirmed, holding that because there was sufficient evidence in the record for the district court to find, beyond a reasonable doubt, that, while operating his motor vehicle, Soucy was impaired, to some extent, by his consumption of prescription drugs, the district court did not err in its judgment.

Chad Gurney was convicted of murder and arson following a jury-waived trial. The Supreme Court affirmed the judgment of the trial court, holding that the court did not err in (1) denying Gurney's motions to suppress evidence found on his Facebook account, laptop computer, and cell phone; (2) admitting evidence of a reference to a beheading video found in unallocated space on the hard drive of Gurney's laptop computer; (3) not addressing in its findings the journals and emails that Gurney offered as evidence of his preexisting and ongoing psychosis; and (4) finding that Gurney did not carry his burden of proving that he suffered from a mental disease or defect that substantially affected his ability to appreciate the wrongfulness of his conduct.

Mallory McPartland appealed from a judgment of conviction entered in the criminal docket upon her conditional guilty plea to operating under the influence (OUI) following the denial of her motion to suppress evidence. McPartland argued that the suppression court erred in concluding that the police officer she encountered at an OUI roadblock had a reasonable articulable suspicion of impairment that was sufficient to justify additional sobriety screening. The Supreme Court affirmed the suppression court's finding that the officer had reasonable suspicion to refer McPartland to secondary screening in this case, holding that the court correctly concluded that satisfaction of the reasonable articulable suspicion standard justifies directing a motorist to secondary screening following an initial roadblock stop.

After a jury trial, Kenny Ouellette was convicted of reckless conduct. Ouellette appealed, arguing that the superior court erred in (1) declining to instruct the jury on his justification of self-defense to the charge of reckless conduct, and (2) failing to inform the jury of the parties' out-of-course resolution that resulted in a dismissal of a count of criminal mischief stemming from the same incident. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's instruction to the jury that it could not consider self-defense as to the charge of reckless conduct was erroneous, and (2) the error was not harmless. Remanded for a new trial.

Following a jury trial, Jesse Guyette was convicted of unlawful possession of scheduled drugs. Guyette appealed, arguing that the superior court erred by admitting several statements at trial pursuant to the Me. R. Evid. 804(b)(3) exception to the hearsay rule for statements against penal interest. The Supreme Court vacated Guyette's conviction, holding (1) the trial court abused its discretion by admitting the out-of-court statements of a person who was not a codefendant at trial but whose statements implicated Guyette because the statements did not fall within the Rule 804(b)(3) hearsay exception; and (2) the court's error in admitting those statements was not harmless.

Raymond Cloutier appealed from a judgment entered in the district court granting Robin Turner's motion to enforce the child support provisions of a 1992 amended divorce judgment. The Supreme Court affirmed the judgment, holding (1) Turner had standing to bring the motion even though the children were above the ages of eighteen because, although the obligation to provide future support ends when the child reaches majority, liability for arrearages does not terminate then; (2) where child-support arrearages are considered money judgments and there is no statute of limitations for money judgments, Turner's claim of overdue child support was not time-barred; (3) the court's failure to apply the statute of limitations did not deprive Cloutier of his constitutional right of equal protection because Cloutier was not treated any differently than fathers who are subject to child support enforcement stemming from a paternity action; and (4) Cloutier failed to make the showing necessary to establish the defense of laches.