Justia Maine Supreme Court Opinion Summaries

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

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