Justia Civil Rights Opinion Summaries

Timothy Burns was convicted of theft of unauthorized taking, a Class C offense, following a jury trial. The Supreme Court affirmed the conviction and sentence, holding (1) because the jury could not have rationally found from the evidence that Burns was guilty of theft of property with a value of less than $1000 and because a theft by unauthorized taking is a Class C offense when the property stolen is valued between $1000 and $10,000, the court's failure to instruct the jury concerning the amount necessary to elevate a theft to a Class C offense was harmless; (2) the evidence was sufficient to establish Burns' guilt beyond a reasonable doubt because the jury rationally could have found from the evidence presented at trial that Burns was guilty of the theft of the check involved in this case, and the jury could only have found that the amount stolen was the amount of the check; and (3) the superior court did not err by sentencing Burns to twenty-two months' incarceration.

While on patrol, a state police trooper clocked a Pontiac traveling at a speed well above the speed limit. As the trooper was making a turn to pursue the car, a motorcycle driven by Ronald LaPlante passed him. The trooper lost sight of the car but did come upon the motorcycle. The trooper stopped LaPlante for the sole purpose of asking about the direction of the Pontiac but obtained sufficient for the State to charge LaPlante with criminal operating under the influence. LaPlante moved to suppress the evidence obtained during the vehicle stop, but the superior court denied the motion. LaPlante was then convicted of operating under the influence. On appeal, the Supreme Court vacated the judgment, holding (1) a law enforcement officer's investigation of a third party's civil speeding offense does not justify the discretionary seizure of a motorist in the absence of reasonable articulable suspicion, and (2) the superior court erred when it denied LaPlante's motion to suppress. Remanded.

After pleading guilty to criminal charges, Terry Chesnel received judgments of conviction requiring him to pay $3700 in court fines. Soon after Chesnel was incarcerated, the Department of Corrections began withdrawing twenty-five percent of all funds deposited into Chesnel's prison account to satisfy his court fines. Chesnel later filed a petition for post-conviction review, asserting that he had been denied effective assistance of counsel. His petition did not mention the Department's collection of funds from his prison account. The superior court denied Chesnel's petition, and no appeal was taken. Two years later, Chesnel filed a motion to modify the conditions governing the collection of his court fines while he was in prison. The superior court denied the motion. Chesnel appealed, contending, inter alia, that the Department's collection of funds without notice or hearing was an unconstitutional taking and violation of due process. The Supreme Court dismissed the appeal, holding that because Chesnel did not raise the issue through a petition for post-conviction review, the superior court did not have jurisdiction to entertain Chesnel's motion. Remanded to the superior court for a dismissal of the motion.

Defendant Stanley Ward was convicted of kidnapping, attempted murder, and robbery and was sentenced to an aggregate sentence of fifty years, all but forty-five years suspended. Ward challenged the sentences on the grounds that (1) the length of the sentences, both individually and collectively, violated his constitutional protection against cruel or unusual punishment; (2) when the court found the facts necessary to impose consecutive sentences, resulting in a longer period of incarceration than the statutory maximum for any of his convictions individual, it violated his constitutional right to trial by jury; and (3) the court erred in its application of Me. Rev. Stat. 1256 in imposing consecutive sentences. The Supreme Court affirmed the judgment of the trial court, holding (1) Ward's collective and individual sentences did not constitute cruel or unusual punishment; (2) the superior court's imposition of consecutive sentences did not violate Ward's right to trial by jury; and (3) the superior court properly determined that the statute did not bar the imposition of consecutive sentences under these circumstances.

Appellant, a former corrections officer, was dismissed after an administrative hearing on November 4, 2009. On November 18, the commissioners issued their written decision which containted their findings and rationale. On December 18, the appellant filed a compliant asserting a due process claim pursuant to 42 U.S.C. 1983 and a wrongful termination claim pursuant to 30-A M.R.S. 501(3)(A). At issue was what constitutes ânotice of any actionâ to trigger M.R. Civ. P. 80B(b)âs 30-day time limit for filing an administrative appeal. The Supreme Court vacated and remanded the lower courtâs dismissal of appellantâs due process and wrongful termination claims as untimely, holding that Rule 80B(b)âs time limit for seeking review of a decision to dismiss an employee does not commence until the employee receives a written decision of the county commissioners or personnel board. The Court also held that because appellant did not have an opportunity to address his suspension before he was terminated, direct review pursuant to Rule 80B(b) would not provide an adequate remedy for appellantâs Section 1983 claim; therefore, denial of appellantâs right to due process of law was independent of his administrative appeal.

âPenelope W.â appealed lower courtsâ decisions that involuntarily committed her to a state psychiatric center. In all aspects of her case, Penelope represented herself. The trial court concluded that she was mentally ill, and that she presented a likelihood of serious harm to herself and others. The appellate court denied Penelopeâs appeal because she failed to comply with the courtâs briefing requirements. On appeal to the Supreme Court, Penelope argued that she should not have been allowed to proceed at trial without counsel, particularly since involuntary commitment was at stake. The Supreme Court found although there is a limited right to self-representation in criminal cases, the same cannot be said for a civil commitment proceeding. The Court affirmed the trial courtâs decision that ordered Penelope to be committed.

Plaintiffs-Appellants Dwayne and Debbie Bonney appeal the lower courtâs decision granting summary judgment to Defendant-Appellee Stephens Memorial Hospital. The Court vacated the decision on the state law claims, and remanded the case back to the lower court for further proceedings. Plaintiffs drove themselves to the hospital after a violent assault that took place at their home. A hospital security guard overheard the Plaintiffsâ discussion with nursing staff, and said that he was going to call the police. Despite the Plaintiffsâ protest, the guard made the call, and disclosed all information he overheard. Based on this information, police obtained a warrant to search the Plaintiffs' home, found evidence of marijuana cultivation, leading to the Plaintiffsâ subsequent indictment and conviction on drug trafficking charges. Citing a violation of state and federal law for unauthorized disclosure of health care information, the Plaintiffs brought suit seeking damages from the hospital and the unnamed guard. On appeal, the Court found that the lower court erred in dismissing the Plaintiffsâ state claims under summary judgment: â30-A.M.R.S. § 287 does not shield health care providers for the unauthorized reporting of confidential health care information when the reporting involved is not related to an examination of a victim performed to obtain evidence for the prosecution.â The Court upheld dismissal of the Plaintiffsâ claims under the Health Insurance Portability and Accountability Act (HIPPA) finding the law authorizes no private cause of action.