Articles Posted in Maine Supreme Judicial Court

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The Supreme Judicial Court affirmed two separate judgments of the probate court granting the petitions of half-sisters’ maternal grandmother to terminate the fathers’ parental rights as part of the proceeding through which the grandmother sought to adopt the children, holding that the fathers were not deprived of due process and equal protection of the law when the court denied the fathers’ motions for an order requiring the provision of rehabilitation and reunification services. The judicial termination proceedings in these consolidated cases did not involve the Department of Health and Human Services. The fathers argued that they were constitutionally entitled to the services that are ordinarily provided in a title 22 child protection action after a court has found abuse or neglect or has placed a child in foster care under the supervision of the Department. The Supreme Court disagreed, holding that the probate court (1) did not violate the fathers’ constitutional rights by denying the fathers’ motions for orders of rehabilitation and reunification services; and (2) did not err in determining that each father’s parental rights should be terminated. View "In re Adoption of Riahleigh M." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of three counts of possession of sexually explicit material of a minor under age twelve, holding that the court did not err in denying Defendant’s motion to suppress evidence seized pursuant to a search warrant. On appeal, Defendant argued that the search warrant was stale, failed to describe the items to be seized with “scrupulous exactitude,” as required by the First Amendment, and otherwise failed to describe the places to be searched and the items to be seized with sufficient particularity. The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress, holding (1) the trial court did not err in ruling that the information the court relied on was not stale; (2) the warrant’s description of the items to be seized and the purpose for their seizure did not implicate the heightened “scrupulous exactitude” standard; and (3) the warrant was not overbroad and satisfied the constitutional requirement for particularity. View "State v. Roy" on Justia Law

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The Supreme Court vacated the judgment of the superior court affirming the decision of the Department of Health and Human Services to deny John Doe’s request for a review of the Department’s 2003 substantiation of him for sexual abuse of a minor, holding that the Department’s denial of Doe’s request as untimely violated Doe’s procedural due process rights. In 2003, the Department mailed a letter to Doe informing him that he had been substantiated for sexual abuse of a minor. When the Department substantiated Doe, a paper review established by a 2000 Department policy was the only appeal process available to an individual seeking to challenge a substantiation fining. The Department did not adopt the 2000 policy pursuant to the Maine Administrative Procedure Act (APA). In 2017, the Department notified Doe that, based on his 2003 substantiation, his presence in a home where children were residing could lead to the removal of those children. Doe requested a hearing to review his 2003 substantiation, but the Department denied the request as untimely. The superior court affirmed. The Supreme Judicial Court vacated the judgment, holding that the Department’s 2000 policy was judicially unenforceable, the 2003 Department letter constitutionally flawed, and the Department’s denial of Doe’s request as untimely a violation of Doe’s procedural due process rights. View "Doe v. Department of Health & Human Services" on Justia Law

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The Supreme Judicial Court affirmed Defendant’s judgment of conviction for operating under the influence (Class D), holding that the motion court did not err by denying Defendant’s motion to suppress evidence of Defendant’s blood-alcohol level obtained following two warrantless blood draws. On appeal, Defendant argued that the motion court erred in finding that exigent circumstances justified two warrantless blood draws and thus denying his motion to suppress evidence of his blood-alcohol level obtained from the second blood draw. The Supreme Judicial Court disagreed, holding that the evidence supported the motion court’s finding that there were exigent circumstances that negated the warrant requirement for both blood draws. View "State v. Martin" on Justia Law

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The Supreme Judicial Court affirmed orders of the trial court denying Appellant’s motions to suppress evidence that was seized by the local police department and state police and then returned to the individuals who reported the items stolen, holding that Appellant received a fair trial and that the search warrants were valid. On appeal, Appellant argued that the State failed to preserve exculpatory evidence in violation of his due process right to a fair trial, and that two search warrants failed to designate all of the items to be seized with adequate particularity, making the warrants unconstitutionally vague. The Supreme Judicial Court affirmed, holding (1) even if Appellant made the threshold showing that the evidence at issue was lost or destroyed, he did not demonstrate that any of the evidence had apparent exculpatory value at the time the items were returned to their owners; and (2) the search warrants identified the items to be seized with as much particularity as was possible under the circumstances. View "State v. Winchester" on Justia Law

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The Supreme Judicial Court vacated the judgment of the superior court dismissing as untimely Appellant’s petition seeking review of a rule promulgated by the Department of Corrections (DOC), holding that the court should have treated Appellant’s petition as a complaint for declaratory judgment and allowed him to amend his petition to that effect. In his petition, Appellant, a prisoner at the Maine State Prison, claimed that the DOC had promulgated and enforced a rule that violated Me. Rev. Stat. 34-A, 3039 and several provisions of the state and federal Constitutions. The superior court dismissed the petition without reaching the merits of Appellant’s statutory and constitutional arguments. The Supreme Judicial Court vacated the judgment, holding that, given Appellant’s clear challenge to the legality of the DOC rule itself and not its application to his individual circumstances, the court abused its discretion in declining to allow Appellant to amend his complaint and seek relief through a declaratory judgment action. View "Sweeney v. Department of Corrections" on Justia Law

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The Supreme Judicial Court affirmed in part and vacated in part an order of the trial court suppressing evidence seized pursuant to a warrantless search of Defendant’s jacket and vehicle, holding that the search of Defendant’s jacket was a lawful search incident to arrest but that the search of Defendant’s vehicle was not supported by probable cause and was outside the scope of a vehicle search incident to arrest. The trial court concluded that the searches of Defendant’s jacket and vehicles and the seizure of the evidence was not supported by probable cause and violated Defendant’s Fourth Amendment rights. The State appealed, arguing that the search of Defendant’s jacket was a lawful search incident to her arrest and that the evidence discovered in the jacket supported the subsequent search for the illegal drugs discovered in Defendant’s vehicle. The Supreme Judicial Court agreed with respect to the search of Defendant’s jacket but vacated the suppression order as to the evidence found in the vehicle. View "State v. Pagnani" on Justia Law

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The Supreme Judicial Court affirmed Defendant’s conviction for aggravated trafficking of scheduled drugs following his guilty plea, holding that the motion court did not err in denying Defendant’s motion to suppress evidence seized by, and statements made to, police officers after he was arrested without a warrant. On appeal, Defendant argued that the police lacked sufficient probable cause to believe that he was engaged in criminal conduct to justify his warrantless arrest. Therefore, Defendant argued, the statements made and evidence seized after the arrest were subject to suppression. The Supreme Judicial Court disagreed, holding (1) sufficient corroborated information warranted any prudent and cautious person to believe that Defendant was committing the offense of heroin trafficking; and (2) therefore, law enforcement officers properly made the warrantless arrest. View "State v. Journet" on Justia Law

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The Supreme Judicial Court held that an individual resident of Maine was not entitled to a Maine income tax credit for any portion of business taxes imposed by New Hampshire on a New Hampshire limited liability company of which the Maine resident was a member. Appellants, Maine residents, appealed from the judgment of the Business and Consumer Docket affirming the State Tax Assessor’s denial of a tax credit for a share of a New Hampshire business taxes paid by a New Hampshire LLC proportional to the membership interest that Appellants had in the LLC. The court reasoned that no income tax credit applied because (1) the New Hampshire business taxes were imposed on the LLC and were not an “amount of income tax imposed on [an] individual,” Me. Rev. Stat. 36, 5217-A; and (2) Maine’s tax statutes do not violate the Commerce Clause of the federal Constitution. The Supreme Judicial Court affirmed, holding (1) the lower court correctly interpreted Maine’s income tax statutes; and (2) the court did not err in concluding that Maine’s tax statutes are constitutionally sound. View "Goggin v. State Tax Assessor" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated operating under the influence and aggravated assault, holding that the court did not err in denying Defendant’s motion to suppress evidence of his alcohol level determined from a sample of Defendant’s blood that was seized without a warrant. Specifically, the Court held (1) probable cause existed for a law enforcement officer to obtain a sample of Defendant’s blood in the context of an operating under the influence investigation, and (2) exigent circumstances justified the warrantless blood draw because Defendant was about to go into surgery where he would not be available for a blood draw as part of the State’s investigation and his body would further metabolize any alcohol that might be in his blood. View "State v. Palmer" on Justia Law