Justia Constitutional Law Opinion Summaries

Employee filed this action against Employer and her four individual supervisors (Supervisors), claiming whistleblower discrimination pursuant to the Whistleblowers' Protection Act (WPA) and the Maine Human Rights Act (MHRA) and sex discrimination pursuant to the MHRA. The superior court granted Supervisors' motion to dismiss, finding they could not be held individually liable pursuant to the WPA and the MHRA. The court then entered summary judgment in favor of Employer on all claims. Employee appealed, contending (1) summary judgment for Employer was improper because she presented a prima facie case of whistleblower discrimination and there remained material facts in dispute, and (2) the dismissal of her claims against Supervisors was improper. The Supreme Court affirmed with respect to the sex discrimination claim and the dismissal of Supervisors but vacated the judgment with respect to the whistleblower discrimination claim against Employer, holding (1) material facts remained in dispute regarding Employee's whistleblower claim; but (2) the WPA and MHRA do not provide for individual supervisor liability. View "Fuhrmann v. Staples the Office Superstore E., Inc." on Justia Law

Following a nonjury trial, Defendant was convicted of domestic violence assault. Defendant's sentence included a period of two years of probation with a requirement that he participate in a certified batterers' intervention program. Defendant contended that his sentence violated the Equal Protection clauses of the U.S. and Maine Constitutions because, he asserted, a woman convicted of the same crime could not be sentenced to a term of probation of more than one year. The Supreme Court vacated the sentence and remanded for additional proceedings because there was no factual record from which the Court could evaluate Defendant's and the State's arguments. View "State v. Mosher" on Justia Law

The Board of Licensure in Medicine revoked Petitioner's medical license. The superior court dismissed Petitioner's complaint seeking judicial review, concluding (1) it lacked subject matter jurisdiction to review the Board's decision because the district court had exclusive jurisdiction to review nonconsensual license-revocation orders pursuant to Me. Rev. Stat. 10, 8003(5); and (2) Petitioner's 42 U.S.C.S. 1983 claim should be dismissed because the Board members had authority to revoke her license and were immune from suit. The Supreme Court affirmed, holding (1) the superior court properly dismissed Petitioner's petition for review of the Board order revoking her license because the district court had exclusive jurisdiction in such matters; and (2) because the Board acted within its authority in revoking Petitioner's license and, on appeal, Petitioner did not otherwise assert a denial of her constitutional rights, Petitioner's section 1983 claim was properly dismissed. View "Michalowski v. Bd. of Licensure in Med." on Justia Law

Defendant appealed from a judgment of conviction of one count of murder and one count of manslaughter entered in the trial court following a jury trial. Defendant argued that the trial court erred in denying his motion to suppress a confession, other statements, and physical evidence found as a result of the statements. The Supreme Court affirmed the judgment, holding that the trial court did not err in (1) finding Defendant was not in custody during the first interrogation; (2) failing to suppress Defendant's post-warning statements because the detectives' actions did not reflect a deliberate strategy to use "Miranda-in-the-middle," a two-step interrogation procedure; and (3) concluding that the State proved beyond a reasonable doubt that Defendant's post-warning statements were voluntary in light of the totality of the circumstances. View "State v. Nightingale" on Justia Law

Defendant was charged with the murder of her estranged husband. Following a jury trial, Defendant was found guilty of attempted murder, elevated aggravated assault, and false public alarm or report. Defendant appealed, asserting that the trial court made several evidentiary errors and that improper statements made by the prosecutor during the trial constituted prosecutorial misconduct that deprived her of a fair trial. The Supreme Court concluded that no evidentiary errors occurred and focused its discussion on Defendant's assertions of prosecutorial misconduct. The Court affirmed the judgment, holding that any prosecutorial misconduct, even considered cumulatively, did not affect the jury's verdict, and therefore, Defendant received a fair trial. View "State v. Dolloff" on Justia Law

Defendant appealed from a judgment of conviction entered in the trial court finding him guilty of four counts of criminal threatening with a dangerous weapon, eleven counts of criminal restraint with a dangerous weapon, twenty-two counts of kidnapping, one count of burglary, and one count of criminal restraint. The Supreme Court affirmed, holding (1) Defendant was not denied his right to speedy trial; (2) Defendant was not denied his right to self-representation; (3) the jury instructions accurately and fairly informed the jury in all necessary aspects of the law; (4) the court did not err by not dismissing the kidnapping charge; (5) there was sufficient evidence for the jury to find Defendant held the kidnapping victims for a "substantial period of time"; and (6) the court properly imposed consecutive sentences. View "State v. Hofland" on Justia Law

Defendant appealed from a judgment of conviction entered by the trial court following his conditional guilty plea to manslaughter. Defendant contended (1) the trial court erred in denying his motion to suppress statements he made to police officers during the investigation of his infant daughter's death, and (2) the juvenile court erred by admitting hearsay evidence during Defendant's juvenile bind-over hearing. The Supreme Court affirmed the judgment, holding (1) any statements made by Defendant during interrogations were not subject to the requirements of Miranda and were therefore not excludable on those grounds, the court properly considered Defendant's juvenile status, and the court did not err in concluding that Defendant's confession was voluntary; and (2) the court did not err by treating the hearsay testimony during the bind-over hearing as reliable, and therefore, its admission was not error. View "State v. Jones" on Justia Law

A jury convicted Defendant of unlawful sexual contact and of violating a condition of release. Defendant challenged his convictions on appeal, asserting (1) the superior court erred in denying his request to instruct the jury on assault as a lesser-included offense of unlawful sexual contact, and (2) there was insufficient evidence to find that he had "contact" with the victim in violation of his conditions of release. The Supreme Court (1) vacated the judgment of conviction for unlawful sexual contact, holding that the court failed to properly instruct the jury on assault as a lesser-included offense of unlawful sexual contact; and (2) affirmed the judgment of conviction for violating a condition of release, holding that there was sufficient evidence in the record upon which the jury could find every element of the offense of violating a condition of release beyond a reasonable doubt. View "State v. Gantnier" on Justia Law

Norman Budge and twenty-eight additional parties (collectively, Employees) filed a complaint for review of government action for the Town of Millinocket's (Town) amendments to its personnel policy originally adopted as a town ordinance. In the most recent amendment, the Town reduced its obligation for paying for the health insurance plan for its employees and established a new policy for the health insurance offered to retirees that resulted in the Town reducing its payment of the retirees' premiums. Employees alleged that, regardless of the policy language, this reduction was inconsistent with promises made to them either when they were hired or during their tenure with the Town. The superior court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the personnel policy did not create an enforceable contract between the Town and its employees; (2) the Town was not bound to pay Employees' retirement group hospitalization and life insurance premiums by virtue of promissory estoppel; and (3) the Town's reduction in benefits did not result in an unconstitutional taking. View "Budge v. Town of Millinocket" on Justia Law

After a jury trial, Appellant was convicted of gross sexual assault and two counts of aggravated assault. On appeal Appellant challenged the trial court's failure to sanction the State for what he asserted was a discovery violation and the court's exclusion of his computer expert from testifying at trial. The Supreme Court affirmed, holding (1) the court acted well within its discretion in denying Appellant's motion for sanctions; and (2) the court did not exceed its discretion in excluding Appellant's computer expert, given that the delay in supply the expert report to the State was due to Appellant's own failure to pay his expert, the information supplied to the State days before the trial was not complete, and the substantial deference afforded the trial court in determining the admissibility of expert testimony. View "State v. Silva" on Justia Law