Justia Civil Rights Opinion Summaries

Appellant Timothy Daniels appealed a superior court's grant of summary judgment in favor of Defendants Narraguagus Bay Health Care Facility and North Country Associates, Inc. Appellant contended that the court erred in concluding that Narraguagus and North Country were entitled to judgment as a matter of law on his disability discrimination and retaliation claims made pursuant to Maine's Human Rights Act. Appellant suffered a work-related injury to his right shoulder in 2007 and thereafter was given work restrictions by his physician that prevented him from performing all of the work duties he had previously handled. In 2008, Appellant underwent surgery and then began a leave of absence. A few months later, Appellant notified his employer that he was applying for more leave at her insistence. In that letter, Appellant also reported that he had been cleared for light duty work, accused his supervisor of refusing to accommodate his disability, and asked for light duty work. No work was afforded to Appellant as a result of that letter. Appellant suffered another work-related injury to his right shoulder in 2009, and, although he did not lose any time from work as a result of that injury, he was restricted to modified duty for the next three months. During that period Appellant was disciplined for performance issues. Early in November 2009, when Daniels no longer had any work restrictions, a new Narraguagus administrator gave Appellant a performance improvement plan for failing to complete some tasks at all and failing to complete other tasks on time. In November, 2009, in response to the complaint that he filed in 2008, the Commission issued Appellant a right-to-sue letter pursuant to the Human Rights Act. When state regulators visited Narraguagus to conduct a licensing inspection, they uncovered issues that resulted in fines to the facility. Narraguagus blamed Appellant for the negative inspection and terminated his employment on January 29, 2010. After his termination, Appellant filed a two-count complaint against Narraguagus and North Country. On appeal, Appellant advanced two theories of liability against North Country: (1) that it can be liable because it is part of an integrated enterprise with Narraguagus, and (2) that it acted in Narraguagus’s interest in discriminating against him. Finding multiple issues of disputed facts regarding North Country's involvement in the actions that Appellant claimed constituted discrimination and retaliation, the Supreme Court vacated the grant of summary judgment in favor of Defendants, and remanded the case for further proceedings.

Richard Herzog was convicted of domestic violence assault and sentenced to twenty days in jail, all suspended, and two years of probation with conditions, including the condition that Herzog could not possess or use unlawful drugs or alcohol. The Supreme Court (1) affirmed the judgment of conviction, holding that the district court properly applied the law of self-defense and did not err in its factual findings; and (2) affirmed the sentence as modified, holding that the term of probation exceeded the statutory maximum, and thus, the sentence was adjusted to decrease the period of probation from two years to one year.

Following a jury trial, Timothy Mooney was found guilty of trafficking in prison contraband. Mooney appealed, arguing that the superior court erred by (1) allowing a corrections officer to testify about details of the incident giving rise to Mooney's criminal charge, and (2) allowing an investigator to testify as to additional charges that would have been brought against Mooney had another inmate cooperated with the investigation. The Supreme Court vacated Mooney's conviction, holding (1) the trial court did not abuse its discretion by admitting the corrections officer's testimony; (2) the trial court erred by admitting the investigator's irrelevant testimony in evidence; and (3) the error was not harmless.

Defendant Cory LaForge was charged with criminal operating under the influence. LaForge filed a motion to suppress evidence obtained as a result of the stop of his vehicle, arguing that the stop was not justified by an objectively reasonable suspicion of criminal conduct. The district court agreed and granted LaForge's motion. The Supreme Court vacated the suppression order, holding that, as matter of law based on the facts found by the motion judge, the stop of LaForge's vehicle by a police officer was justified based on an objectively reasonable articulable suspicion. Remanded for entry of an order denying the motion to suppress.

Following a joint jury trial, Jeffrey Williams was convicted of intentional or knowing murder and conspiracy to commit murder. The Supreme Court affirmed Williams's convictions, holding (1) Williams was not denied a fair trial when the court denied his motion to sever the trial, or, in the alternative, to hold a joint trial but with a separate jury for each defendant; (2) the court did not abuse its discretion in prohibiting cross-examination of a cooperating witness regarding Williams's prior arrests; (3) certain comments by the prosecutor in relation to the cooperating witness did not constitute improper vouching; and (4) the evidence was sufficient to support Williams's convictions.

Following a jury trial, Darlene George was convicted of intentional or knowing murder and conspiracy to commit murder. The Supreme Court affirmed the judgment, holding (1) the circuit court did not err in denying George's motion to suppress her grand jury testimony, as the use of the testimony at trial did not violate George's right against compulsory self-incrimination and the testimony was voluntary; (2) the court did not err in denying George's co-defendant's motion to sever the trial; (3) the indictment was sufficient; (4) the evidence was sufficient to support George's convictions; and (5) George's conviction was fundamentally fair and did not violate due process.

Following a jury trial, Kirk Gould was convicted of gross sexual assault (Class A) and gross sexual assault (Class B). Gould appealed. The Supreme Court affirmed, holding (1) the trial court properly denied Gould's motion to suppress his confession as involuntary where the totality of the circumstances demonstrated that Gould's confession was voluntary; (2) Gould was not denied a fair trial based on the prosecutor's alleged misrepresentation of the evidence in closing argument because the prosecutor did not engage in misconduct; and (3) the trial court did not err by denying Gould's motions for a new trial and sanctions based on an alleged discovery violation.

Jack Bailey appealed from a judgment of conviction of ten counts of gross sexual assault and two counts of unlawful sexual conduct entered in the superior court, arguing that the court erred in denying his motion to suppress live-witness testimony because the testimony should have been suppressed as fruit of the poisonous tree in violation of the Fourth Amendment. The State contended that the court erred in granting Bailey's motion to suppress evidence discovered during a police search of Bailey's residence. The Supreme Court affirmed the judgment, holding (1) the circuit court correctly found that Bailey's consent to the search of his apartment was not voluntary, and therefore, the evidence found during the search was properly suppressed; and (2) the circuit court did not err in denying the motion to suppress the live-witness testimony after considering the factors set out in United States v. Ceccolini in determining the admissibility of the witnesses' testimony.

After a jury-waived trial, David Christian was convicted of three counts of theft by unauthorized taking, a Class D theft, and one count of theft by unauthorized taking, a Class E theft. Christian appealed, contending that the evidence was insufficient to establish beyond a reasonable doubt that he intended to deprive his employer of rent payments and that the court erred by classifying two counts as Class D theft rather than Class E theft. The Supreme Court vacated and modified the judgment, holding (1) the record contained sufficient evidence to support the court's findings regarding Christian's intent; but (2) the court erred in its classification of the contested counts. Remanded for resentencing.

MacImage of Maine and its principal asked six Maine counties to provide to them, in a specified digital format, copies of every document contained in the counties' registries of deeds, including the indexes to the recorded documents. The counties agreed to provide electronic copies of the registries' recorded documents, but disputes over the fees that the counties could charge for the requested electronic information precipitated this litigation. The superior court determined that the counties could not charge the fees that they proposed in their responses to the requests. The Supreme Court vacated the judgment of the superior court, which entered its judgment before recent legislation was passed. The Court held that the recent legislation was applicable to the dispute and that the responses of all but two of the six counties agreeing to provide the requested records in bulk and setting the costs for transferring the data fell within the law's parameters for reasonable fees. Remanded for entry of judgment in favor of those four counties and for further proceedings regarding the remaining two counties.