Justia Constitutional Law Opinion Summaries

Plaintiff filed an action in the U.S. district court against a Maine police officer, alleging that the officer used force in arresting Plaintiff in violation of state and federal law. A jury found the officer liable on Plaintiff's state law negligence claim and awarded Plaintiff $125,000 in damages. The district court amended the judgment to reduce the damages award to $10,000 pursuant to Me. Rev. Stat. 14, 8104-D. Plaintiff appealed to the First Circuit Court of Appeals. The First Circuit certified two questions for the Supreme Court's review. The Court answered only the first question by holding that whether or not an insurance policy is available to cover a judgment against a government employee sued in his personal capacity, the applicable limit on the award of damages is $10,000 pursuant to section 8104-D rather than $400,000 or the policy limit pursuant to Me. Rev. Stat. 14, 8105(1) and 8116. View "Fortin v. Titcomb" on Justia Law

This appeal resulted from a high-speed chase involving Patrick Smith, who was driving a motorcycle, and Andrew Feeney, a Cumberland County Sheriff's Deputy. After Feeney observed Smith's motorcycle traveling above the speed limit, Feeney pursued Smith until Smith crashed and fell off the motorcycle. Smith's Estate sued the County, former Sheriff Mark Dion, and Feeney for negligence. The superior court granted summary judgment for the County and Feeney, concluding that they were entitled to discretionary function immunity pursuant to the Maine Tort Claims Act. The Supreme Court affirmed but for different reasons, holding that because the record did not contain any evidence to support a finding that Defendants' actions were a cause of Smith losing control of his motorcycle, the Estate could not maintain its claim of negligence. View "Estate of Smith v. Cumberland County" on Justia Law

After the State brought a criminal proceeding against Mark Strong, the court initiated jury selection through a process that had the practical effect of excluding the public, including the media, from voir dire. After Maine Today Media, Inc.'s request that the court open the voir dire process to the public was denied, Maine Today filed a motion to intervene, which the trial court denied. Maine Today filed an interlocutory appeal. The Supreme Court (1) vacated the denial of the motion to intervene and allowed intervention for the limited purpose of the matters addressed in this appeal; and (2) vacated the court's order barring the public from the entirety of the voir dire process. Remanded to the trial court to conduct the remaining voir dire in a presumptively public manner. View "State v. Strong" on Justia Law

After a jury trial, Defendant was found guilty of intentional or knowing murder for killing a sixteen-year-old girl, who was found buried with her wrists bound in duct tape, behind Defendant's mother's home. Defendant was sentenced to forty-seven years' incarceration. The Supreme Court affirmed. Defendant subsequently moved for additional DNA analysis and a new trial, claiming that a trace amount of male DNA previously found in a clipping from the duct tape had been further analyzed, and that Defendant was excluded as the source of that DNA. The post-conviction court denied Defendant's motion for a new trial, holding that the newly discovered DNA evidence did not make a different verdict probable due to the strong evidence of Defendant's guilt and the limited nature of the additional DNA test results. The Supreme Court affirmed, holding that the court did not err in its findings of fact, misapply the relevant statute, or abuse its discretion in denying the motion for a new trial. View "State v. Reese" on Justia Law

During her employment with Employer, Appellant applied to open a registered medical marijuana dispensary. Appellant was later terminated from her employment. Appellant filed a complaint against Employer, alleging in count I of her complaint that her termination was a violation of the Maine Medical Use of Marijuana Act (Act). Appellant argued that her application for a license to operate a medical marijuana dispensary was authorized conduct within the meaning of the Act and her subsequent termination was thus a penalty prohibited by the Act. The superior court granted Employer's motion to dismiss with respect to several counts, including count I. The parties later stipulated to the dismissal of the remaining counts. The Supreme Court affirmed, holding that the Act does not create a private right of action against private employers, but rather, protects against prosecution and penalties by governmental regulatory entities. View "Savage v. Me. Pretrial Servs., Inc." on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and criminal mischief. The Supreme Court affirmed, holding that the jury rationally could have found every element of the offenses beyond a reasonable doubt, as (1) the evidence presented was sufficient to support the jury's findings that Defendant obtained and intended to deprive the State of possession of property with a value greater than $1,000; and (2) the evidence was sufficient to support the jury's findings that Defendant intentionally, knowingly, or recklessly damaged or destroyed property of the State without reasonable grounds to do so. View "State v. Reed" on Justia Law

After a jury trial, Defendant was convicted for the intentional or knowing murder of his roommate. Defendant appealed, arguing that the trial court erred in concluding that he waived his Fifth Amendment privilege against self-incrimination and ordering him to answer a question posed by the State on cross-examination. The Supreme Court affirmed the conviction, holding that the trial court did not abuse its discretion (1) in determining that Defendant waived his Fifth Amendment privilege and in reasoning that the disputed question posed by the State was within the scope of his testimony on direct examination; and (2) in instructing the jurors that they could consider Defendant's unprivileged refusal to answer the State's question on cross-examination. View "State v. Butsitsi" on Justia Law

In the late 1990s, Bryan Carrier pled guilty to three counts of vehicular manslaughter and three counts of aggravated operating under the influence. The judgment and commitment notified Defendant that his license was suspended for life on the manslaughter counts. In 2011, Carrier petitioned for reinstatement of his license. After a hearing, a hearing officer of the Secretary of State's Bureau of Motor Vehicles denied Carrier's petition based on the opposition of the victims' families. The superior court denied Carrier's petition for judicial review. The Supreme Court affirmed, holding that the reinstatement statute allows for consideration of the opinions of the victims and their families. View "Carrier v. Sec'y of State" on Justia Law

When Restaurant was denied a requested liquor license by the Town of Bingham, Restaurant appealed to the Department of Public Safety. After a hearing, a Department hearing officer also denied the license. On appeal, Restaurant asserted various independent claims alleging constitutional and statutory violations by the Department and Town. The appellate court found in favor of Defendants on Restaurant's independent claims but, on the merits, remanded the matter to the Department after concluding that an appeal of a municipality's denial of a liquor license could only be decided by the Commissioner of Public Safety and not a hearing officer. On remand, the Commissioner of the Department denied the license application. The Supreme Court affirmed, holding (1) the deficiencies in the Department's notice to Restaurant of the hearing on Restaurant's requested liquor license constituted harmless error in the circumstances presented by this case; (2) The Department had sufficient grounds on which to deny Restaurant's liquor license; and (3) the court did not err in entering a judgment against Restaurant on its 42 U.S.C.S. 1983 claims. View "Antler's Inn & Rest., LLC v. Dep't of Pub. Safety" on Justia Law

After a jury trial, Defendant was convicted of intentional and knowing murder. The trial court sentenced Defendant to thirty-five years in prison. Defendant appealed, arguing (1) the court erred in denying him a new trial based on the State's failure to produce exculpatory evidence, (2) the court violated the equal protection right of a juror removed from the panel given his inability to deliberate past 5:08 p.m. for religious reasons, and (3) there was insufficient evidence to support his conviction. The Supreme Court affirmed the judgment, holding (1) Defendant received a fair trial in this matter; (2) there was no disparate treatment of the juror, and therefore, the juror's equal protection rights were not violated; and (3) there was no error in the trial court's entry of the judgment of conviction or its sentencing analysis. View "State v. Carr" on Justia Law