Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of knowing or intentional murder and sentenced to two concurrent sentences of life imprisonment. The Supreme Court affirmed the judgment and sentence, holding (1) the evidence presented at trial was sufficient for the jury to find all of the elements of the crime charged; (2) the sentencing court did not misapply sentencing principles; and (3) the sentencing court did not abuse its discretion when it determined that aggravating and mitigating factors did not require a departure from the basic sentence, and the court did not impermissibly or unconstitutionally impose a sentence that was more severe based upon Defendant’s exercise of his right to a trial.View "State v. Hayden" on Justia Law

After a jury trial, Defendant was found guilty of intentional or knowing murder and sentenced to seventy years imprisonment. Defendant appealed, arguing, inter alia, that the trial court violated his right to confront witnesses by admitting medical examiner testimony because the testimony relied in part on an autopsy report created by a different medical examiner who did not testify at trial. The Supreme Court affirmed, holding (1) pursuant to State v. Mitchell, the admission of the medical examiner’s testimony was not a violation of the Confrontation Clause; and (2) Defendant’s remaining assertions of error were unavailing.View "State v. Mercier" on Justia Law

After a jury trial, Defendant was found guilty of several sex offenses. The Supreme Court affirmed after clarifying the conduct the State was required to prove in order to prove the element of penetration, holding that the trial court did not err in (1) denying Defendant’s motion for a judgment of acquittal on the charge of unlawful sexual conduct, as the jury could have rationally made the finding that the State proved beyond a reasonable doubt every element of the offense; and (2) conducting voir dire, as no individual voir dire member disclosed a general bias against a defendant with mental illness.View "State v. Gladu" on Justia Law

After a jury trial, Defendant was convicted of criminal operating under the influence and refusing to sign a uniform summons and complaint. On appeal, Defendant argued, among other things, that he did not properly waive his right to be assisted by counsel at trial. The Supreme Court vacated the judgment, holding that the record did not reflect - either through Defendant’s own responses to the court regarding the trial process, counsel’s statements regarding Defendant’s waiver, or evidence regarding whether Defendant was informed about the trial process - that Defendant voluntarily, knowingly, and intelligently waived his constitutional right to counsel.View "State v. Hill" on Justia Law

After a jury trial, Defendant was found guilty of operating after habitual offender revocation. Defendant appealed, arguing (1) the trial court erred when it failed to clarify the definition of “public way” as defined in Me. Rev. Stat. 17-A, 505(2); (2) the statute’s language is confusing and unconstitutionally vague; and (3) the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) Defendant failed to preserve her clarification argument; (2) the language of the statute is outdated and confusing but describes a certain type of public way with sufficient certainty to survive a due process challenge; and (3) the evidence was sufficient to support the verdict.View "State v. Stanley" on Justia Law

After a jury trial, Defendant was found guilty of manslaughter. Defendant appealed, arguing that the trial court erred in denying his motion to suppress because he was subjected to custodial interrogation and did not receive Miranda warnings and because he was in a state of shock and emotional distress that rendered his statements involuntary. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Defendant’s statements were not made in the course of custodial interrogation for purposes of Miranda; and (2) the trial court did not err in determining that Defendant’s statements were made voluntarily. View "State v. Bryant" on Justia Law

Defendant’s probation officer asked Defendant to come to the probation office. When Defendant complied, he met two state troopers who sat down with him and asked him about a theft at the victim’s apartment. After the interview, Defendant made incriminating statements. Defendant was charged with burglary and theft by unauthorized taking or transfer. Defendant moved to suppress the statements he made to law enforcement. The trial court determined that Defendant spoke voluntarily and that he was not in custody, and therefore, Miranda warnings were not required. Defendant was subsequently convicted of theft by unauthorized taking or transfer. The Supreme Court affirmed, holding (1) the trial court did not err in determining that Miranda warnings were unnecessary because Defendant was not in custody; (2) the trial court did not err in concluding that the confession was voluntary; and (3) the evidence was sufficient to support the conviction. View "State v. Kittredge" on Justia Law

After a jury-waived trial, Defendant was convicted of failing to provide his correct, name, address, and date of birth; possession or distribution of dangerous knives; and refusing to submit to arrest or detention. The Supreme Court vacated Defendant’s conviction of failing to give his correct name, address, and date of birth but otherwise affirmed, holding (1) the trial court did not violate Defendant’s Confrontation Clause rights at a suppression hearing by admitting testimony of police officers because the testimony was not hearsay; and (2) the evidence presented at trial was insufficient to sustain Defendant’s conviction of failing to give his correct name, address, and date of birth. View "State v. Johnson" on Justia Law

Plaintiff filed a complaint against Defendant asserting multiple intentional torts and alleging that Defendant sexually assaulted Plaintiff in the early 1970s when Plaintiff was a child and Defendant was a Roman Catholic pastor. On remand, the superior court entered summary judgment in favor of Defendant, concluding that Plaintiff’s complaint was time-barred. At issue on appeal was whether the statute of limitations was tolled due to Defendant’s move to Massachusetts during the applicable time frame. The Supreme Court affirmed, holding that Defendant established, without dispute of material facts, that he was amenable to service because Maine’s long-arm statute permitted service of the complaint in Massachusetts and that Plaintiff could have located him through reasonable effort and served him by any means other than publication. View "Angell v. Hallee" on Justia Law

In 2013, Defendant was tried on a charge of domestic violence assault. During the trial proceedings, the trial court granted Defendant’s motion for a mistrial after finding manifest necessity to declare a mistrial. Concluding that the mistrial did not involve prosecutorial misconduct, the trial court ruled that the State was entitled to retry its case. Defendant appealed, arguing that double jeopardy barred retrial. The Supreme Court affirmed, holding that because Defendant consented to a mistrial, and because intentional prosecutorial misconduct did not bar a retrial, there was no barrier to retrial under the double jeopardy clause. View "State v. Johnson" on Justia Law