In State v. Connor, the Maine Supreme Judicial Court, sitting as the Law Court, upheld a trial judge’s denial of a motion to suppress evidence. Although the evidence presented in the suppression hearing seemed adequate to support the denial of the motion, the trial judge failed to clearly state his conclusions of law when denying the motion. However, the Law Court mistook the ambiguous conclusions of law as ambiguous findings of fact. Because the findings of fact were ambiguous in the court’s view, the majority and dissenting opinions spent the bulk of their energies discussing how the court should review a case when the findings of fact are ambiguous. However, as this Note will discuss, the Law Court essentially turned a straightforward case into a convoluted one by delving into the findings of fact “issue” in such detail. In essence, the findings of fact issue should not have been addressed at all. The Law Court simply mistreated an ambiguity in the trial judge’s legal conclusion as an ambiguity in its factual conclusion. Since the court reviews legal conclusions de novo, an ambiguous legal conclusion by a trial judge should not matter since the court will revisit the issue in full on appeal. Accordingly, the court should have simply undertaken a de novo review of the law applied to the facts in the case. However, because it mistook a legal conclusion for a factual one, the court spent considerable time discussing how to review a case when a historical fact is not clear from the findings of fact—a situation this Note will call the “Hypo.” Along with examining the facts and opinions of the Connor case, and explaining how the court should have dealt with the case, this Note will also address the Hypo, and how the court should address an ambiguity in the findings of fact.
Christopher S. Boulos,
Findings of Fact vs. Conclusions of Law: How the Law Court Complicated the Case of State v. Connor,
Me. L. Rev.
Available at: http://digitalcommons.mainelaw.maine.edu/mlr/vol62/iss2/17