Articles Posted in Civil Rights

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Me. Rev. Stat. 17-A, 1112 is facially constitutional, and, in the instant case, the trial court’s admission of a lab certificate in lieu of live witness testimony pursuant to that statute was not a violation of Defendant’s right of confrontation. Defendant appealed from a judgment, entered after a jury trial, convicting her of unlawful trafficking of a schedule W drug. At issue was whether the trial court’s admission of a lab certificate identifying a substance exchanged in a controlled purchase as methamphetamine. The court admitted the lab certificate in lieu of the testimony of the chemist pursuant to section 1112. The Supreme Court affirmed, holding (1) section 1112 is facially constitutional; (2) Defendant’s failure to timely demand a live witness pursuant to section 1112 effected a voluntary, knowing, and intentional waiver of her Confrontation Clause rights; and (3) therefore, the trial court did not err in allowing into admission the chemist’s certificate in lieu of live testimony. View "State v. Jones" on Justia Law

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The motion court did not err by applying the inevitable discovery doctrine to deny Defendant's motion to suppress evidence of drugs found on his person before the issuance of a search warrant. The Unified Criminal Docket found Defendant guilty of unlawful trafficking in scheduled drugs and ordering a criminal forfeiture. In denying Defendant’s motion to suppress drug evidence, the trial court found that law enforcement officers’ warrantless entry into an apartment was not justified by exigent circumstances but that it was highly likely that the officers inevitably would have discovered drugs. The Supreme Court affirmed the denial of the motion to suppress, holding (1) the motion court did not err by finding that the police inevitably would have discovered the drug evidence at issue by lawful means; and (2) application of the inevitable discovery doctrine does not create an incentive for police misconduct and does not significantly weaken Fourth Amendment protections. View "State v. Prinkleton" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the district court, entered after a jury trial, finding that Defendant had committed the civil violations of improperly displaying a registration plate and failing to register a vehicle that is operated or remains on a public way. Contrary to Defendant’s arguments on appeal, the Supreme Court held (1) the district court did not err in finding that the State established the elements of each violation; and (2) the court proceedings below did not violate the Due Process Clause, the Equal Protection Clause, or the Americans with Disabilities Act. View "State v. Chase" on Justia Law

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The Supreme Judicial Court remanded the judgment of the superior court permanently enjoining Ronald Champagne from, among other things, “threatening or using physical force or violence against any person by reason of that person’s race, color, religion, sex, ancestry, national origin, physical or mental disability or sexual orientation” in violation of the Maine Civil Rights Act. Champagne filed motions to amend the judgment and for further findings of fact and conclusions of law, asserting that the injunction was overbroad. The superior court denied the motions. The Supreme Judicial Court remanded the matter for the superior court to make findings supporting the granting of and the broad scope of the injunction and to explain its rationale in doing so. View "State v. Champagne" on Justia Law

Posted in: Civil Rights

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The Supreme Judicial Court affirmed the judgment of the superior court granting the Department of Environmental Protection’s request for a permanent injunction prohibiting Dubois Livestock, Inc. and the Randrick Trust (collectively, Appellants) from denying the Department access for solid waste inspections. The court held (1) the superior court did not err in concluding that Me. Rev. Stat. 38, 347-C and 1304(4-A) permit the Department to enter Appellants’ property without consent or an administrative search warrant; and (2) the warrantless searches authorized by these statutes do not violate Appellants’ constitutional right to be free from unreasonable searches and seizures. View "State v. Dubois Livestock, Inc." on Justia Law

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The Supreme Judicial Court affirmed the order of the trial court denying Defendant’s motion to dismiss a complaint charging him with operating under the influence (OUI). In his motion to dismiss, Defendant argued that because he had already been convicted on a complaint containing the identical charging language, forcing him to defend against the charge violated his rights under the federal and state constitutions to be free from double jeopardy. The Supreme Judicial Court affirmed, holding that, for the purpose of double jeopardy analysis, the two complaints did not arise from the same act or transaction and, therefore, the Double Jeopardy Clause did not require the dismissal of the complaint at issue. View "State v. Martinelli" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of criminal threatening with a dangerous weapon, following a two-day jury trial. Contrary to the arguments raised by Defendant on appeal, the Supreme Court held (1) the trial court did not abuse its discretion or violate Defendant’s rights under the Confrontation Clause by allowing testimony about statements of an unavailable witness; and (2) there was sufficient evidence to support the guilty verdicts on the two counts of criminal threatening with a dangerous weapon. View "State v. Hall" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court denying Appellant’s petition for postconviction relief on the grounds of ineffective assistance of counsel. Appellant was found guilty of gross sexual assault, assault, and tampering with a victim. The Supreme Court affirmed on appeal. Appellant then filed a petition for postconviction review, arguing in part that he was deprived of the effective assistance of trial counsel because trial counsel opened the door to damaging evidence or failed to object to certain testimony elicited on cross-examination. The trial court denied the petition. The Supreme Judicial Court remanded the matter, holding that, contrary to the trial court’s conclusion, Appellant did not waive his challenge to counsel’s effectiveness in responding to the testimony of a specific witness at trial. View "Salley v. State" on Justia Law

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In this class action, the Supreme Judicial Court affirmed the judgment of the superior court declining to grant declaratory and injunctive relief from alleged violations of constitutional rights arising from the York County Probate Court schedule ordered by former York Court Probate Judge Robert Nadeau. While Plaintiff’s appeal was pending, Judge Nadeau filed a motion to dismiss, arguing that the case became moot when he lost the election for the probate judgeship. The Supreme Judicial Court held (1) this appeal was is moot; and (2) the superior court did not err in determining that Judge Nadeau’s altered court schedule did not result in delays in these routine cases that rose to the level of constitutional deprivations, and Judge Nadeau did not violate the class members’ substantive due process rights as litigants in the York County Probate Court. View "Legrand v. York County Judge of Probate" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the postconviction court denying Defendant’s petition for postconviction review seeking relief from a judgment convicting Defendant of theft by misapplication of property and securities fraud. In his petition for postconviction review Defendant alleged ineffective assistance of trial counsel during plea negotiations and at trial, resulting in prejudice. In its judgment, the court found that Defendant’s arguments did not warrant relief. The Supreme Judicial Court affirmed, holding that the postconviction court was not compelled to find that Defendant established deficient representation or prejudice during either plea negotiations or trial. View "Philbrook v. State" on Justia Law