clear and convincing evidence standard (Maine) · Go Syfert
← Maine issues

clear and convincing evidence standard in Maine

28 Maine opinions name it 2 courts 1984–2024 3 in the last five years

The cases below were cited by Maine courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Taylor v. Commissioner of Mental Health & Mental Retardationgreen
me · 1984 · cited in 4 Maine opinions naming this issue, 1996–2014
2 sentences

2014Further, “the policies that motivated the imposition of the clear and convincing evidence standard apply with equal force at both the factfind-ing and appellate stages.” Taylor, 481 A.2d at 153 (quotation marks omitted). [¶ 56] Viewing Bailey’s actions as identified in the six counts of misconduct, we conclude that Bailey met his burden of proof by clear and convincing evidence only with respect to the question of whether he recognizes the wrongfulness and seriousness of having sent an ex parte communication to Judge Paul (Count VII).

2003In order to meet the clear and convincing evidence standard of proof, the party bearing the burden of persuasion may prevail only if she can "place in the ultimate factfinder an abiding conviction that the truth of [her] factual contentions are 'highly probable.’ ” Taylor v. Comm'r of Mental Health & Mental Retardation, 481 A.2d 139, 153 (Me.1984) (quoting Colorado v. New Mexico, 467 U.S. 310, 316 , 104 S.Ct. 2433 , 81 L.Ed.2d 247 (1984)).

34
Matthew W. Pitts v. Amanda M. Mooregreen
me · 2014 · cited in 3 Maine opinions naming this issue, 2016–2017
2 sentences

2017See Pitts v. Moore, 2014 ME 59, ¶ 27 , 90 A.3d 1169 (establishing a clear and convincing evidence standard in the absence of legislation when interference with fundamental rights is at issue); cf. In re Marcia E. 2012 ME 139, ¶ 4 , 58 A.3d 1115 .

2017See Pitts v. Moore, 2014 ME 59, ¶ 27 , 90 A.3d 1169 (establishing a clear and convincing evidence standard in the absence of legislation when interference with fundamental rights is at issue); cf. In re Marcia E. 2012 ME 139, ¶ 4 , 58 A.3d 1115 .

23
Hiller v. Fauseygreen
pa · 2006 · cited in 2 Maine opinions naming this issue, 2024–2024
2 sentences

2024They urge us to go beyond the clear-and-convincing-evidence standard and determine whether termination of the mother’s parental rights, based on a finding that she is unfit due to her inability to resolve jeopardy and take responsibility for the child and his complicated medical needs, was the least restrictive means to achieve a compelling government interest, see Hiller v. Fausey, 904 A.2d 875, 885-86 (Pa. 2006), given that the State has failed to provide 24/7 private nursing care to the child that could enable the mother to care for him. [¶16] We agree that we must review this case with reg

2024They urge us to go beyond the clear-and-convincing-evidence standard and determine whether termination of the mother’s parental rights, based on a finding that she is unfit due to her inability to resolve jeopardy and take responsibility for the child and his complicated medical needs, was the least restrictive means to achieve a compelling government interest, see Hiller v. Fausey, 904 A.2d 875, 885-86 (Pa. 2006), given that the State has failed to provide 24/7 private nursing care to the child that could enable the mother to care for him. [¶16] We agree that we must review this case with reg

22
Santosky v. Kramergreen
scotus · 1982 · cited in 3 Maine opinions naming this issue, 1998–2021
2 sentences

2019The Court further held that "determination of the precise burden equal to or greater than [clear and convincing evidence] is a matter of state law properly left to state legislatures and state courts." Id. at 769-70 , 102 S.Ct. 1388 . [¶8] We have since affirmed that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases, In re Crystal S. , 483 A.2d 1210 , 1210, 1213 (Me. 1984), and stated that "[t]he Maine Legislature appropriately adopted the clear and convincing evidence standard in the statute governing the termination

2019The Court further held that "determination of the precise burden equal to or greater than [clear and convincing evidence] is a matter of state law properly left to state legislatures and state courts." Id. at 769-70 , 102 S.Ct. 1388 . [¶8] We have since affirmed that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases, In re Crystal S. , 483 A.2d 1210 , 1210, 1213 (Me. 1984), and stated that "[t]he Maine Legislature appropriately adopted the clear and convincing evidence standard in the statute governing the termination

13
Addington v. Texasgreen
scotus · 1979 · cited in 1 Maine opinions naming this issue, 2021–2021
1 sentence

2021See Addington v. Texas, 441 U.S. 418 (1979) and Santosky v. Kramer, 455 U.S. 745 (1982).

11
Guardianship of Jakob A. Gionestgreen
me · 2015 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See Guardianship of Gionest, 2015 ME 154, ¶5 , 128 A.3d 1062 ; Pitts v. Moore, 2014 ME 59, ¶ 27 , 90 A.3d 1169 .

2016See Guardianship of Gionest, 2015 ME 154, ¶5 , 128 A.3d 1062 ; Pitts v. Moore, 2014 ME 59, ¶ 27 , 90 A.3d 1169 .

11
In re Amanda H.green
me · 2007 · cited in 1 Maine opinions naming this issue, 2011–2011
2 sentences

2011Cf. In re Amanda H., 2007 ME 43, ¶ 3 , 917 A.2d 1120, 1120-21 (holding that “[a] court may not enter an order terminating parental rights in the absence of an explicitly stated finding, by clear and convincing evidence, that termination is in the best interest of the child....

2011Cf. In re Amanda H., 2007 ME 43, ¶ 3 , 917 A.2d 1120, 1120-21 (holding that “[a] court may not enter an order terminating parental rights in the absence of an explicitly stated finding, by clear and convincing evidence, that termination is in the best interest of the child....

11
Maine Eye Care Associates P.A. v. Gormangreen
me · 2006 · cited in 1 Maine opinions naming this issue, 2008–2008
2 sentences

2008See Maine Eye Care Assoc. v. Gorman, 2006 ME 15, ¶¶ 1, 22 , 890 A.2d 707, 708, 712 .

2008See Maine Eye Care Assoc. v. Gorman, 2006 ME 15, ¶¶ 1, 22 , 890 A.2d 707, 708, 712 .

11
Petit v. Key Bank of Mainegreen
me · 1996 · cited in 1 Maine opinions naming this issue, 2008–2008
1 sentence

2008See Petit v. Key Bank of Maine, 688 A.2d 427, 431 (Me. 1996) (declining to apply the clear and convincing evidence standard to the "fraud or intimidation" element of the tort of wrongful interference with an advantageous economic relationship).

11
In Re Thomas B.green
me · 1998 · cited in 1 Maine opinions naming this issue, 2001–2001
2 sentences

2001See In re Thomas B., 1998 ME 236, ¶ 2, 719 A.2d 529, 530 .

2001See In re Thomas B., 1998 ME 236, ¶ 2, 719 A.2d 529, 530 .

11
Littlefield v. Adlergreen
me · 1996 · cited in 1 Maine opinions naming this issue, 2000–2000
2 sentences

2000See Littlefield v. Adler, 676 A.2d 940, 942 (Me. 1996). .

2000See Littlefield v. Adler, 676 A.2d 940, 942 (Me.1996). [3] On January 16, 1998, the trial court further ordered Green Tree to pay $2100 toward the Pattens' attorney fees. [4] Title 14 M.R.S.A. § 1901(2)(A) (Supp.1999) provides: "A party must appeal from a District Court judgment in an action of foreclosure and sale directly to the Supreme Judicial Court within 30 days of the judgment." See id. [5] The trial court also denied Green Tree's motion for clarification and amendment of judgment. [6] The trial court awarded attorney fees to the Pattens in a January 16, 1998 order.

11
Tuttle v. Raymondgreen
me · 1985 · cited in 1 Maine opinions naming this issue, 1993–1993
1 sentence

1993Tuttle v. Raymond, 494 A.2d 1353, 1363 (Me.1985). 9 .

11
Application of Hughesgreen
me · 1991 · cited in 1 Maine opinions naming this issue, 1992–1992
1 sentence

1992The Board of Bar Examiners contends that certain findings of fact are unsupported by the record and that the single justice failed to apply the clear and convincing evidence standard required by our opinion on the Board’s first appeal, Application of Hughes, 594 A.2d 1098, 1101 (Me.1991) (Hughes I).

11
Allen v. Radackgreen
sdd · 1977 · cited in 1 Maine opinions naming this issue, 1984–1984
11
People v. Kinggreen
illappct · 1983 · cited in 1 Maine opinions naming this issue, 1984–1984
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maine. Read the followed side critically anyway.

Also cited on this issue (17)

CaseCitedYears
In re Thomas H. green
me · 2005
2 sentences

2019Specifying again that all findings were made by clear and convincing evidence, the court found that "[w]hen the children came into care, the parents continued their unsafe [lifestyle], failed to alleviate jeopardy, and failed to recognize their need to understand the needs of their children and what role they play in the Department taking their children into care." The record supports the court's findings, to the clear and convincing evidence standard, that at least one ground of parental unfitness had been proved, see 22 M.R.S. § 4055(1)(B)(2)(b)(ii), and that termination of the parents' righ

2019Specifying again that all findings were made by clear and convincing evidence, the court found that "[w]hen the children came into care, the parents continued their unsafe [lifestyle], failed to alleviate jeopardy, and failed to recognize their need to understand the needs of their children and what role they play in the Department taking their children into care." The record supports the court's findings, to the clear and convincing evidence standard, that at least one ground of parental unfitness had been proved, see 22 M.R.S. § 4055(1)(B)(2)(b)(ii), and that termination of the parents' righ

22019–2019
Guardianship of Sebastien Chamberlain green
me · 2015
2 sentences

2019The Court further held that "determination of the precise burden equal to or greater than [clear and convincing evidence] is a matter of state law properly left to state legislatures and state courts." Id. at 769-70 , 102 S.Ct. 1388 . [¶8] We have since affirmed that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases, In re Crystal S. , 483 A.2d 1210 , 1210, 1213 (Me. 1984), and stated that "[t]he Maine Legislature appropriately adopted the clear and convincing evidence standard in the statute governing the termination

2019The Court further held that "determination of the precise burden equal to or greater than [clear and convincing evidence] is a matter of state law properly left to state legislatures and state courts." Id. at 769-70 , 102 S.Ct. 1388 . [¶8] We have since affirmed that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases, In re Crystal S. , 483 A.2d 1210 , 1210, 1213 (Me. 1984), and stated that "[t]he Maine Legislature appropriately adopted the clear and convincing evidence standard in the statute governing the termination

22015–2019
In re Marcia E. green
me · 2012
2 sentences

2017See Pitts v. Moore, 2014 ME 59, ¶ 27 , 90 A.3d 1169 (establishing a clear and convincing evidence standard in the absence of legislation when interference with fundamental rights is at issue); cf. In re Marcia E. 2012 ME 139, ¶ 4 , 58 A.3d 1115 .

2017See Pitts v. Moore, 2014 ME 59, ¶ 27 , 90 A.3d 1169 (establishing a clear and convincing evidence standard in the absence of legislation when interference with fundamental rights is at issue); cf. In re Marcia E. 2012 ME 139, ¶ 4 , 58 A.3d 1115 .

22017–2017
Colorado v. New Mexico green
scotus · 1984
2 sentences

2003In order to meet the clear and convincing evidence standard of proof, the party bearing the burden of persuasion may prevail only if she can "place in the ultimate factfinder an abiding conviction that the truth of [her] factual contentions are 'highly probable.’ ” Taylor v. Comm'r of Mental Health & Mental Retardation, 481 A.2d 139, 153 (Me.1984) (quoting Colorado v. New Mexico, 467 U.S. 310, 316 , 104 S.Ct. 2433 , 81 L.Ed.2d 247 (1984)).

2003In order to meet the clear and convincing evidence standard of proof, the party bearing the burden of persuasion may prevail only if she can "place in the ultimate factfinder an abiding conviction that the truth of [her] factual contentions are 'highly probable.’ ” Taylor v. Comm'r of Mental Health & Mental Retardation, 481 A.2d 139, 153 (Me.1984) (quoting Colorado v. New Mexico, 467 U.S. 310, 316 , 104 S.Ct. 2433 , 81 L.Ed.2d 247 (1984)).

21996–2003
In Re the Revocation of the License of Polk green
nj · 1982
1 sentence

2021In re Polk, 449 A.2d 7 (N.J. 1981 ); Jones v. Conn. Med.

12021–2021
Steadman v. Securities & Exchange Commission green
scotus · 1981
1 sentence

2021Several of the courts that have upheld the preponderance of the evidence standard have pointed to the United State Supreme Court's decision in Steadman v. SEC, 450 U.S. 91 (1981) as recognizing that the clear and convincing evidence standard is not required in a proceeding to revoke a license to practice a profession.

12021–2021
In Re Crystal S. green
me · 1984
1 sentence

2019The Court further held that "determination of the precise burden equal to or greater than [clear and convincing evidence] is a matter of state law properly left to state legislatures and state courts." Id. at 769-70 , 102 S.Ct. 1388 . [¶8] We have since affirmed that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases, In re Crystal S. , 483 A.2d 1210 , 1210, 1213 (Me. 1984), and stated that "[t]he Maine Legislature appropriately adopted the clear and convincing evidence standard in the statute governing the termination

12019–2019
In Re Hannah S. green
me · 2016
2 sentences

2018LEGAL ANALYSIS [¶ 6] “We review the court’s factual findings for clear error, evaluated pursuant to the clear and convincing evidence standard of proof.” In re Hannah S., 2016 ME 32, ¶ 7 , 133 A.3d 590 .

2018LEGAL ANALYSIS [¶ 6] “We review the court’s factual findings for clear error, evaluated pursuant to the clear and convincing evidence standard of proof.” In re Hannah S., 2016 ME 32, ¶ 7 , 133 A.3d 590 .

12018–2018
Rideout v. Riendeau green
me · 2000
2 sentences

2016This record does not compel findings, to the clear and convincing evidence standard, of harm that will have a “dramatic, and even traumatic effect upon [this] child’s well-being,” Rideout, 2000 ME 198, ¶ 26 , 761 A.2d 291 .

2016This record does not compel findings, to the clear and convincing evidence standard, of harm that will have a “dramatic, and even traumatic effect upon [this] child’s well-being,” Rideout, 2000 ME 198, ¶ 26 , 761 A.2d 291 .

12016–2016
In re R.M. green
me · 2015
2 sentences

2016In re R.M., 2015 ME 38, ¶ 7 , 114 A.3d 212 .

2016In re R.M., 2015 ME 38, ¶ 7 , 114 A.3d 212 .

12016–2016
In Re Michaela C. green
me · 2002
2 sentences

2014See 22 M.R.S. § 4055(1)(B)(2)(b)(ii); In re Michaela C., 2002 ME 159, ¶¶ 17-23 , 809 A.2d 1245 .

2014See 22 M.R.S. § 4055(1)(B)(2)(b)(ii); In re Michaela C., 2002 ME 159, ¶¶ 17-23 , 809 A.2d 1245 .

12014–2014
State v. Barnes green
me · 2004
2 sentences

2010State v. Barnes, 2004 ME 105, ¶ 5 , 854 A.2d 208, 209-10 . [¶ 10] The issue presented here is an assertion that, while the trial court applied the standard of proof in accordance with the then-governing statute, that statute was unconstitutional because it should have required at least a clear and convincing evidence standard of proof.

2010State v. Barnes, 2004 ME 105, ¶ 5 , 854 A.2d 208, 209-10 . [¶ 10] The issue presented here is an assertion that, while the trial court applied the standard of proof in accordance with the then-governing statute, that statute was unconstitutional because it should have required at least a clear and convincing evidence standard of proof.

12010–2010
In Re Heather G. green
me · 2002
1 sentence

2002Id. at ¶ 8, 805 A.2d at 251 . [¶4] Our opinion in Heather G. was not a requirement or even a suggestion that, in their fact-findings in termination of parental rights cases, the trial courts need to individually list all of the witnesses.

12002–2002
State Ex Rel. Barnes v. Behan green
sd · 1963
2 sentences

1984Barnes v. Behan, 80 S.D. 370 , 124 N.W.2d 179 (1963), was invalidated on constitutional grounds by a federal district court, which substituted a clear-and-convincing-evidence standard. 11 See Allen v. Radack, 426 F.Supp 1052.

1984Barnes v. Behan, 80 S.D. 370 , 124 N.W.2d 179 (1963), was invalidated on constitutional grounds by a federal district court, which substituted a clear-and-convincing-evidence standard. 11 See Allen v. Radack, 426 F.Supp 1052.

11984–1984
State v. Taylor green
mont · 1971
2 sentences

1984The decision of the Montana Supreme Court adopting the reasonable doubt standard, see State v. Taylor, 158 Mont. 323 , 491 P.2d 877 (1971), cert. denied, 406 U.S. 978 , 92 S.Ct. 2428 , 32 L.Ed.2d 677 (1972), was effectively overruled by a change in the Montana Code.

1984The decision of the Montana Supreme Court adopting the reasonable doubt standard, see State v. Taylor, 158 Mont. 323 , 491 P.2d 877 (1971), cert. denied, 406 U.S. 978 , 92 S.Ct. 2428 , 32 L.Ed.2d 677 (1972), was effectively overruled by a change in the Montana Code.

11984–1984
Wayman Patterson v. Russell Lash, Warden green
scotus · 1972
1 sentence

1984The decision of the Montana Supreme Court adopting the reasonable doubt standard, see State v. Taylor, 158 Mont. 323 , 491 P.2d 877 (1971), cert. denied, 406 U.S. 978 , 92 S.Ct. 2428 , 32 L.Ed.2d 677 (1972), was effectively overruled by a change in the Montana Code.

11984–1984
DeBorde v. Pinnock green
scotus · 1972
1 sentence

1984The decision of the Montana Supreme Court adopting the reasonable doubt standard, see State v. Taylor, 158 Mont. 323 , 491 P.2d 877 (1971), cert. denied, 406 U.S. 978 , 92 S.Ct. 2428 , 32 L.Ed.2d 677 (1972), was effectively overruled by a change in the Montana Code.

11984–1984

Statutes the citing opinions construe

ME § Me. Rev. Stat. tit. 22, § 4055 (13) ME § Me. Rev. Stat. tit. 22, § 4041 (5) ME § Me. Rev. Stat. tit. 22, § 4005 (4) ME § Me. Rev. Stat. tit. 22, § 4035 (4) ME § Me. Rev. Stat. tit. 22, § 4006 (3) ME § Me. Rev. Stat. tit. 22, § 4038 (3) ME § Me. Rev. Stat. tit. 34-B, § 3864 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TN 374 (1996–2026) TX 306 (1980–2026) CA 247 (1948–2026) OH 185 (1987–2026) PA 115 (1983–2026) NY 101 (1980–2026) OR 97 (1981–2026) AL 81 (1979–2026) MI 79 (1978–2026) IN 64 (1983–2026) FL 62 (1974–2025) IL 58 (1977–2026) NM 52 (1982–2026) DC 49 (1981–2025) CT 47 (1986–2025) AK 44 (1983–2025) KS 40 (1979–2026) GA 37 (1984–2021) OK 35 (1995–2024) LA 35 (1991–2025) MD 34 (1976–2021) AZ 33 (1969–2026) CO 30 (1982–2025) MN 29 (1987–2025) VT 29 (1983–2026) ME 28 (1984–2024) NJ 28 (1979–2021) IA 24 (1982–2025) WA 24 (1986–2026) UT 22 (1951–2024) MO 21 (1992–2025) NC 18 (1983–2024) WI 18 (1967–2025) NV 16 (1986–2025) VA 16 (1995–2022) SD 15 (1975–2011) MA 13 (1984–2026) ND 13 (1986–2026) MS 13 (1989–2024) HI 11 (1963–2026) ID 11 (1975–2024) KY 11 (1986–2025) DE 9 (1982–2025) RI 8 (1989–2026) WY 7 (1986–2022) NE 7 (1993–2024) MT 7 (1997–2021) WV 6 (2019–2026) AR 5 (1979–2016) VI 4 (2013–2025) NH 4 (2011–2025) SC 2 (2001–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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