Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

Defendant was indicted on one count of unlawfully trafficking in scheduled drugs and one count of illegal importation of scheduled drugs. Defendant filed a motion to suppress as evidence illegal drugs seized from him by law enforcement officers after they stopped a vehicle in which he was a passenger. The trial court granted the motion to suppress, concluding that the warrantless search of the clothes Defendant was wearing exceeded the bounds of a valid protective search or justifiable search for contraband. The Supreme Court vacated the suppression order, holding that the search was justified by probable cause and the existence of exigent circumstances, and therefore, the search was constitutional. Remanded. View "State v. Martin" on Justia Law

After the trial court denied Defendant’s motion to suppress evidence derived from internet service provider (ISP) records that the State obtained with a grand jury subpoena, Defendant entered a conditional guilty plea to a charge of possession of sexually explicit materials. Defendant appealed, arguing that the State was required to use the procedure set forth in Me. Rev. Stat. 5, 200-B to obtain the ISP records and that its failure to do so violated his due process rights. The Supreme Court affirmed, holding that section 200-B creates an alternative, not exclusive, method for it to use in seeking ISP records, and therefore, the trial court did not err in finding that the State was not barred from using a grand jury subpoena in obtaining the ISP records. View "State v. Bragdon" on Justia Law

After a jury trial, Defendant was convicted of the Class C charge of sexual abuse of a minor. On appeal, Defendant challenged the admission of testimony of the victim’s mother indicating when the victim told her what had happened and argued that the State committed prosecutorial misconduct in its closing arguments. The Supreme Judicial Court affirmed, holding (1) the trial court properly applied the “first complaint” rule in determining that the mother’s statement was admissible; and (2) any error in the prosecutor’s closing arguments, either individually or cumulatively, did not deprive Defendant of a fair trial. View "State v. Fahnley" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the twenty-two-year delay between the alleged assaults and the indictment. The Supreme Court affirmed, holding (1) the missing recording did not have any apparent exculpatory value at the time it was lost, and Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence, and therefore, Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the loss of the evidence; and (2) Defendant failed to meet his burden of proving that he was prejudiced by the pre-indictment delay. View "State v. Cote" on Justia Law

Marc Chamberlain was the father of two children who had been the care of their maternal grandmother for several years before and following the death of their mother. The children’s maternal grandmother and their maternal aunt petitioned the probate court for appointment as the children’s co-guardians. Chamberlain opposed the petition. The court entered a judgment appointing the grandmother, but not the aunt, as the children’s guardian. In making its decision, the court applied the plain language of Me. Rev. Stat. 18-A, 5-204(d) and found by a preponderance of the evidence that the grandmother was the children’s de facto guardian and that Chamberlain had not consistently participated in the children’s lives. Chamberlain appealed, arguing that section 5-204(d) is facially unconstitutional because it, and the statutes defining its terms, are unconstitutionally vague and violate due process. The Supreme Judicial Court vacated the judgment, holding that the appointment of a guardian over a parent’s objection upon proof by the lower standard of a preponderance of the evidence violates the Due Process Clause of the federal Constitution. Remanded for the court to apply the constitutionally required standard of proof by clear and convincing evidence when applying section 5-204(d). View "In re Guardianship of Chamberlain" on Justia Law

After a jury trial, Defendant was found guilty of murder. After a sentencing hearing, Defendant was sentenced to thirty-eight years’ incarceration and ordered to pay restitution in the amount of $2,261. Defendant appealed from his judgment of conviction and applied to the Sentence Review Panel for the right to appeal his sentence to the Supreme Court. The Panel granted the application, but Defendant’s attorney for the appeals did not brief the sentencing issue. The Supreme Court affirmed the conviction without mentioning the sentence appeal. Defendant filed a petition for post-conviction review, alleging ineffective assistance of counsel on the sentence appeal. The trial court granted the petition and ordered that Defendant’s right to seek review of his sentence be reinstated. The Supreme Court granted Defendant’s motion to reinstate his sentence appeal and affirmed the sentence, holding that Defendant failed to demonstrate any error in the court’s sentencing. View "State v. Butsitsi" on Justia Law

After a jury trial, Defendant was convicted of domestic violence assault. Defendant appealed, arguing that his right to confront witnesses against him under the Confrontation Clauses of the United States and Maine Constitutions was violated when the victim refused to testify and the court admitted hearsay statements from the victim in the form of an emergency 9-1-1 record and the victim’s statements to an EMT. The Supreme Court affirmed, holding that the statements at issue that were admitted in evidence, including the 9-1-1 recording and the statements made to the EMT - were not testimonial in nature, and therefore, the trial court’s rulings did not exceed the bounds set by the U.S. Supreme Court’s jurisprudence. View "State v. Kimball" on Justia Law

After a jury-waived trial, Defendant was convicted of elevated aggravated assault, 17-A Me. Rev. Stat. 208-B(1)(A); elevated aggravated assault, 17-A, Me. Rev. Stat. 208-B(1)(B); and aggravated assault, Me. Rev. Stat. 17-A 208(1)(A). The Supreme Judicial Court vacated the judgment, holding (1) Defendant voluntarily and intentionally waived his constitutional right to testify; (2) the evidence did not compel a determination that Defendant was not criminally responsible for the assault by reason of insanity; but (3) because the court sentenced Defendant for a single incident, and not three separate assaultive acts, the court erred by failing to consolidate the duplicative counts prior to entering its judgment of conviction or its sentence. Remanded for consolidated of the three counts through entry of a single conviction and for entry of a sentence on the single charge. View "State v. Murphy" on Justia Law