Justia Maine Supreme Court Opinion Summaries

A police officer certified to operate the Intoxilyzer, a self-contained breath-alcohol testing apparatus, used the device to test Defendant’s breath-alcohol content. Defendant was subsequently charged with criminal operating under the influence. Pursuant to Me. Rev. Stat. 29-A, 2431(2)(D), Defendant requested that the State produce a qualified witness to testify at his trial. The officer who administered the test was scheduled to testify at trial, but there was no other expert available. Before trial, Defendant filed a motion in limine to exclude the breath-alcohol test result from evidence. The trial court granted the motion, concluding that the State failed to produce a qualified witness. The Supreme Judicial Court vacated the judgment, holding (1) the statute does not require the State to produce expert testimony in order to have the results of the Intoxilyzer admitted into evidence; and (2) the Confrontation Clause of the U.S. Constitution is not implicated when the declarant who administered the breath test is available to testify. View "State v. Tozier" on Justia Law

Defendant pleaded guilty to two counts of misdemeanor assault and was sentenced to one year in jail and one year of probation for each of the assault counts, to be served consecutively. As a condition of probation, Defendant was prohibited from having contact with his son except as specifically permitted by the family court. Defendant filed a motion to amend the conditions of probation. The court denied the motion. Defendant appealed, arguing that the court abused its discretion because the district court, in a collateral parenting action, had already allowed him to have supervised contact with his son. The Supreme Judicial Court affirmed, holding that the court did not unconstitutionally infringe on Collins’s parental rights when it increased the restrictions on his rights of contact with his son that had been set in the separate judicial proceeding. View "State v. Collins" on Justia Law

After a jury trial, Defendant was found guilty of murder and sentenced to forty-five years in prison. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to law enforcement officers in the hours following the murder because he was in a state of intoxication and emotional distress at the time that rendered his statements involuntary. The Supreme Court affirmed, holding that the court did not err in determining that Defendant’s statements to law enforcement were the free choice of a rational mind, were fundamentally fair, and were not a product of coercive police conduct. View "State v. Kierstead" on Justia Law

In two criminal cases, Defendant was indicted on several charges, including unlawful trafficking in synthetic hallucinogenic drugs and conspiracy to commit unlawful trafficking in synthetic hallucinogenic drugs. Defendant filed a motion to dismiss the two cases, arguing that the statute defining a “synthetic hallucinogenic drug” is unconstitutionally vague. The superior court denied the motions to dismiss. Defendant subsequently entered conditional guilty pleas. The Supreme Court affirmed, holding (1) the term “derivative” used in the statute is not unconstitutionally vague; and (2) the statute as a whole is not unconstitutionally vague. View "State v. Reckards" on Justia Law

After a jury trial, Defendant was convicted of aggravated trafficking of scheduled drugs and refusal to submit to arrest or detention. The Supreme Judicial Court affirmed the judgment, holding (1) the trial court did not err or violate Defendant’s constitutional rights by sustaining the State’s objection to Defendant’s cross-examination of a certain witness about the nature of the locale where the crime allegedly occurred based on weaknesses in the probative value of the evidence; and (2) the trial court did not err when it denied Defendant’s motion for a judgment of acquittal, as the evidence was sufficient to support the jury’s guilty verdict. View "State v. Adams" on Justia Law

Between 2002 and 2008, Defendants applied for, were found qualified for, and lived in Section 8 housing, for which the local housing authority paid a substantial rent subsidy to the landlord. Throughout this time, Defendants earned income far in excess of the maximum that would qualify them for Section 8 housing assistance. Defendants were eventually convicted of theft by deception. Defendants appealed, arguing that the trial court erred in admitting into evidence as business records certain forms on which Defendants had provided financial information. The Supreme Court affirmed the judgments, holding that the trial court did not abuse its discretion in admitting the forms into evidence. View "State v. Abdi" on Justia Law

Defendant was charged with unlawful trafficking of scheduled drugs and seeking criminal forfeiture of cash discovered during the search of his vehicle by Maine Drug Enforcement Agency (MDEA) agents. Defendant filed a motion to suppress the evidence gathered from the search. The suppression court denied the motion, concluding that MDEA had sufficient probable cause to search the vehicle based on the totality of the circumstances. The Supreme Court affirmed, holding that because Defendant failed to show his reasonable expectation of privacy in the vehicle, his Fourth Amendment rights were not violated by the search. View "State v. Lovett" on Justia Law

In 2003, John Doe XLVI pleaded guilty to and was convicted of possession of sexually explicit material. When Doe was sentenced, possession of sexually explicit material was not a sex offense requiring registration under Maine’s Sex Offender Registration and Notification Act of 1999 (SORNA), and therefore, Doe was not ordered to comply with SORNA. Possession of sexually explicit material was subsequently added to the list of sex offenses. In 2009, the Legislature amended SORNA to provide that a duty to register “is not triggered by a court determination, but by and upon notification.” In 2012, Doe received a notice of the duty to register. Doe filed this action seeking to enjoin the State from pursuing criminal charges against him for failing to register, alleging, inter alia, that SORNA was an invalid bill of attainder. The superior court rejected Doe’s challenges. The Supreme Court vacated the judgment of the trial court, holding that SORNA is punitive as to offenders who were not sentenced to comply with SORNA when SORNA registration was part of sentencing and who were subsequently subjected to SORNA registration when their earlier offenses were added to the statutory list of sex offenses and registration was removed from sentencing. View "John Doe XLVI v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of perjury. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by allowing the State to introduce testimony regarding Defendant’s silence following his arrest for operating under the influence (OUI) and by allowing the State to refer to this testimony during closing argument; (2) Defendant failed to establish that the trial court abused its discretion in allowing a police officer to testify to his opinion that “there were lies told” during Defendant’s trial for OUI, at which Defendant was acquitted, or that the opinion was prejudicial to him; and (3) admitting the testimony of a Verizon employee about the contents of Defendant’s cell phone billing record that the State offered as the testimony of a custodian of records. View "State v. Wyman" on Justia Law

In 2013, pursuant to the Freedom of Access Act (FOAA), Phillip Bowler requested a copy of the Attorney General’s investigative file concerning a death that occurred in 1953. The Deputy Attorney General denied Bowler access to the file on the ground that it was designated confidential by statute. Bowler appealed to the superior court. The superior court denied the appeal. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the file was made confidential by statute; (2) the Attorney General did not waive the statutory confidentiality of the file by releasing a copy to the decedent’s family; and (3) Defendant’s argument that releasing the file to a family member but not to him violated his constitutional right to equal protection failed. View "Bowler v. State" on Justia Law