Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted for operating after revocation. The Supreme Court affirmed the judgment as amended, holding (1) any error by the trial court in refusing to instruct the jury about certain statutory requirements applicable to written notices of revocation was harmless; and (2) even if the State improperly offered and used documents that Defendant alleged were not properly identified as part of an exhibit but nonetheless were presented to the jury did not rise to the level of obvious and reversible error. Remanded for correction of an improper statutory reference in the judgment and commitment order. View "State v. Garcia" on Justia Law

Defendant was at the place of his employment when his employer asked him to submit to a breath test. The results from the employer’s self-contained portable breath-alcohol testing device showed that Defendant had indicators of alcohol in his system, and Defendant was sent home on unpaid leave. Defendant was driving his van after leaving his place of employment when he was stopped and arrested. A police officer administered several field sobriety tests after stopping Defendant. Defendant was subsequently charged with driving under the influence. Before trial, the court granted the State’s motion in limine to exclude any evidence of the workplace breath-alcohol test to challenge the accuracy of the State’s intoxilyzer test. Defendant entered a conditional guilty plea to the charge then appealed the order on the motion in limine. The Supreme Court vacated the judgment, holding that Defendant was entitled to challenge the reliability of the test results offered by the State by any appropriate means that is otherwise admissible in evidence, and thus the trial court denied Defendant the opportunity to make a formal offer of proof by excluding evidence of the workplace breath-alcohol test. View "State v. Adams" on Justia Law

The trial court revoked Defendant’s probation based on findings that Defendant committed the new crimes of burglary and theft. Defendant appealed, arguing that the trial court erred by admitting, for the purpose of revoking Defendant’s probation, a police officer’s testimony about Defendant’s confessions despite the fact that the statements were obtained in violation of the procedural safeguards established to protect an individual’s Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed the judgment, holding that the exclusionary rule does not apply to probation revocation proceedings unless the probationer presents proof of widespread police harassment or other proof of a serious due process violation. View "State v. Johansen" on Justia Law

Defendant entered a conditional guilty plea to stealing drugs, and judgment was entered accordingly. The Supreme Court affirmed the judgment, holding (1) the court did not err in denying Defendant’s motion to suppress her confession, which was made to police during a voluntary polygraph, as the Defendant’s right to counsel in a separate, prior prosecution did not apply to interrogations arising out of the subsequently, separately alleged offenses; and (2) the pre-charge interrogation regarding the new criminal conduct that gave rise to the current prosecution was not a “critical stage” of the prosecution for purposes of the Sixth Amendment. View "State v. Babb" on Justia Law

After a jury trial, Appellant was found guilty of the murder of the mother of his child. Appellant was sentenced to fifty-five years in prison and ordered to pay restitution. The Supreme Court affirmed the conviction. Appellant filed a pro se petition for post-conviction review, alleging that the trial court violated his right to a public trial. The post-conviction court denied the motion, concluding that Appellant’s Sixth Amendment right to a public trial was not violated. The Supreme Court affirmed, holding (1) trial counsel did not provide ineffective assistance by agreeing to the process of conducting certain aspects of voir dire in chambers, and appellate counsel did not provide ineffective assistance by failing to raise Appellant’s Sixth Amendment claim on direct appeal; (2) the policy of prohibiting spectators from wearing certain types of apparel in the courthouse did not constitute a partial closure of the courtroom; (3) the trial court’s decision to prohibit members of the public from entering the courtroom during witness testimony did not constitute a partial closure; and (4) the post-conviction court properly found that the public was not excluded from the announcement of the verdict. View "Roberts v. State" on Justia Law

In 2007, Plaintiff, frustrated with then-proposed budget cuts to mental health services, sent the Governor a series of emails that were interpreted as threatening. Plaintiff was delivered to MaineGeneral Medical Center for a psychiatric evaluation, where she was eventually subjected to a search and held against her will for the night in a locked room. Plaintiff later filed an action against MaineGeneral and Scott Kemmerer, an emergency room physician, alleging that Defendants deprived her of liberty without due process and subjected her to an unreasonable search in violation of the Maine Civil Rights Act (MCRA). Defendants filed for entry of summary judgment as to the MCRA claims. The court (1) granted the motion as to MaineGeneral, determining that MaineGeneral could not be held vicariously liable for the acts of its employees under the MCRA; and (2) denied the motion as to Kemmerer. The Supreme Court (1) affirmed the denial of summary judgment as to Kemmerer on issues of immunity, holding that Kemmerer was not entitled to absolute immunity or common law qualified immunity from Plaintiff’s MCRA claims; and (2) did not reach Kemmerer’s remaining arguments in this interlocutory appeal. View "Clifford v. MaineGeneral Med. Ctr." on Justia Law

In 2011, the State charged Defendant of aggravated assault and attempted murder. The State alleged that while Defendant and his wife, Lisa, were hiking on Megunticook Mountain, Defendant struck Lisa in the head, dragged her to the edge of a cliff, and threw her over the edge. Shortly thereafter, Defendant was seriously injured after himself falling from a cliff. Defendant was treated at Eastern Maine Medical Center for several days. In 2012, the State obtained a search warrant to obtain Defendant’s personal medical records from the hospital. Defendant filed a motion to suppress his medical records or, in the alternative, to dismiss the charges against him, contending that the State failed to use the proper procedure in obtaining his records, the search warrant was overbroad and not supported by probable cause, and the use of the search warrant during his criminal proceeding violated his due process rights. The trial court declined to suppress Defendant’s medical records. The Supreme Court dismissed Defendant’s appeal as interlocutory, holding that the trial court’s decision not to suppress the evidence did not give rise to a right to an interlocutory appeal. View "State v. Black" on Justia Law

After a jury trial, Defendant was convicted of one count of gross sexual assault. On appeal, Defendant argued that the trial court committed obvious error by permitting the State to introduce evidence of his pre-arrest refusal to voluntarily submit to a warrantless collection of a DNA sample and to argue to the jury that it could infer consciousness of guilt from the refusal. The Supreme Court vacated the judgment, holding that the trial court committed obvious error in admitting evidence of Defendant’s refusal to submit to the warrantless search for the purpose of proving consciousness of guilt. Remanded.View "State v. Glover" on Justia Law

After a jury trial, Defendant was convicted of two counts of gross sexual assault and suspended to twenty years imprisonment. On appeal, Defendant argued that the evidence was insufficient to sustain his convictions, that the prosecutor engaged in impermissible misconduct, and the trial court erred in determining his sentence. The Supreme Court vacated the judgments of conviction, holding (1) the prosecutor violated the state and federal Constitutions by eliciting testimony that Defendant did not return phone calls from police and by arguing to the jury that Defendant’s pre-arrest silence demonstrated consciousness of guilt, and the error seriously affected the fairness and integrity of the judicial proceedings; and (2) the prosecutor committed misconduct by vouching for witness credibility even after the court determined that the statements were impermissible, and the error was not harmless.View "State v. Lovejoy" on Justia Law

After a six-day jury trial, Defendant was convicted of gross sexual assault and sentenced to a term of twenty-four years. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit obvious error in denying Defendant’s access to immigration records pertaining to the victim’s mother; (2) the process used by the trial court to ensure that Defendant, who spoke Spanish, received adequate interpretation services at trial was appropriate and was not in error; and (3) the remainder of Defendant’s arguments on appeal were without merit.View "State v. Marroquin-Aldana" on Justia Law