2020 ME 6
Me.2020Background
- Juvenile (under 15) A.I. was detained at Long Creek Youth Development Center on multiple juvenile petitions filed by the State beginning October 1, 2018 and remained there through June 2019.
- On April 23, 2019 the District Court found A.I. incompetent to proceed but found a substantial probability he could become competent and ordered DHHS to evaluate/treat him.
- A.I. filed a habeas corpus petition (May 14, 2019) and a single justice denied relief on June 10, 2019; A.I. appealed.
- Before oral argument, A.I. was transferred to an out-of-state residential treatment facility and the juvenile charges were dismissed.
- The State moved to dismiss the appeal as moot; the Law Court concluded the controversy was moot and declined to reach the merits because none of the narrow mootness exceptions applied, and dismissed the appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of appeal | Not moot because State retains power to return A.I. to Long Creek; habeas relief still relevant | Moot because A.I. has been released and charges dismissed; no relief would affect him | Appeal is moot: no live controversy remains |
| Exception — capable of repetition but evading review | Delay in placement for incompetent youth is recurring and evades review | Multiple timely detention-review and appeal avenues available; not inherently fleeting | Exception rejected: case does not fit that narrow category |
| Exception — questions of great public concern | Issues about incarceration, resource allocation, agency coordination for incompetent youth warrant guidance | Although matters are of public concern, this case’s unique facts prevent an authoritative precedential rule | Public-interest exception acknowledged but inapplicable: case-specific facts preclude a guiding ruling; appeal dismissed |
Key Cases Cited
- Leigh v. Superintendent, Augusta Mental Health Inst., 817 A.2d 881 (Me. 2003) (mootness doctrine and when courts decline to decide moot issues)
- Mainers for Fair Bear Hunting v. Dep’t of Inland Fisheries & Wildlife, 136 A.3d 714 (Me. 2016) (narrow exceptions allowing review of moot cases)
- Halfway House, Inc. v. City of Portland, 670 A.2d 1377 (Me. 1996) (articulating three mootness exceptions)
- Brunswick Citizens for Collaborative Gov’t v. Town of Brunswick, 189 A.3d 248 (Me. 2018) (factors for public-concern exception)
- State v. J.R., 191 A.3d 1157 (Me. 2018) (importance of rehabilitative treatment and state resource issues for youth)
- Haraden v. State, 32 A.3d 448 (Me. 2011) (agency responsibilities during period of incompetence)
- Or. Advocacy Ctr. v. Mink, 322 F.3d 1101 (9th Cir. 2003) (liberty interests of incapacitated criminal defendants and limits of jail-based treatment)