Justia Maine Supreme Court Opinion Summaries

Defendant operated a returnable bottle redemption center. Defendant was convicted of theft by deception for turning over empty beverage containers that were not from beverages purchased in Maine and accepting deposit refunds and handling fees from Maine beverage distributors for those containers. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the conviction; (2) the trial court did not err in admitting evidence regarding bad acts committed outside the time alleged in the charging instrument; (3) a certain tactic employed by the prosecutor in the case amounted to prosecutorial error, but the error did not prejudice Defendant; and (5) the trial court did not err in failing to give requested jury instructions. View "State v. Woodard" on Justia Law

After a jury trial, Defendant was convicted of seven counts of unlawful sexual contact (Class C) and three counts of unlawful sexual contact (Class B). Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to a detective because he was not advised of his Miranda rights prior to his custodial interrogation and because his statements made prior to and after his arrest were involuntary. The Supreme Court vacated the judgment of conviction and remanded, holding (1) Defendant was not in custody for purposes of the Miranda requirements; but (2) the district court clearly erred in finding that Defendant's statements were voluntary. View "State v. Wiley" on Justia Law

The Town of Madawaska foreclosed on Jeffrey and Jeanne Stoops' property after the Stoops failed to pay municipal taxes. The Town then conveyed the property to Richard and Betty Nelson by municipal quitclaim deed. The Stoopses subsequently filed a complaint against Richard Nelson seeking to quiet title to the property and asking the court to declare the respective rights of the parties to the property. The superior court granted the Nelsons' motion for summary judgment. The Stoopses appealed, arguing (1) the Town failed to give the Stoopses proper notice of the pending foreclosure in violation of their due process rights, and (2) the Town failed to adhere strictly to the requirements of the statutorily outlined steps a municipality must take to foreclose on a municipal tax lien. The Supreme Court affirmed, holding that because the Town complied with the requirements of the statutory scheme and gave the Stoopses sufficient notice, the trial court correctly granted summary judgment in favor of the Nelsons. View "Stoops v. Nelson" on Justia Law

Plaintiffs were sex offenders who were all initially required to register as sex offenders under Maine's Sex Offender Registration and Notification Act (SORNA) of 1999. Some Plaintiffs were later relieved of the registration requirement, but others remained on the registry and had viable claims. Plaintiffs filed actions against several State defendants, alleging, among other things, that SORNA of 1999 was an unconstitutional ex post facto law. The trial court granted the State defendants' motion for summary judgment, concluding that the cases of the Plaintiffs who successfully petitioned to be relieved from the duty to register were moot and that SORNA of 1999 as amended after State v. Letalien was constitutional. The Supreme Court affirmed the trial court's decision that SORNA of 1999 as amended following the Court's decision in Letalien did not violate the constitutional rights of the litigants. View "Doe v. Williams" on Justia Law

Defendant was charged by a fifty-nine-count indictment that included forty-five counts of violation of privacy and one count of conspiracy to commit violation of privacy. Defendant subsequently filed a motion to dismiss the violation of privacy counts, which the trial court granted, concluding that based on the indictment and the State's offer of proof, the State could not prove the crimes as alleged. The State appealed, contending that the court erred in granting the motion because it was untimely and the indictment adequately charged the offenses pursuant to the applicable statutes. The Supreme Court affirmed, holding that because the relevant counts of the indictment, as augmented by the State's offer of proof, failed adequately to charge the offense of violation of privacy, the court properly granted Defendant's motion to dismiss. View "State v. Strong" on Justia Law

Defendant and two co-conspirators pleaded no contest or guilty to various charges. Defendant pleaded guilty to two counts of intentional or knowing murder. The sentencing court sentenced Defendant to two concurrent terms of forty-five years in prison. Defendant appealed, arguing that the court abused its discretion in sentencing him to a longer prison term than that of his two co-conspirators. The Supreme Court affirmed the sentences, holding that, given the court's consideration of the purposes of sentencing, proper completion of the two-step sentencing procedure for murder, articulation of the reasons for the sentence, and explicit discussion of and adjustment for the sentencing inequality at issue, the sentencing court did not abuse its discretion in sentencing Defendant. View "State v. Hamel" on Justia Law

After the State brought a criminal proceeding against Mark Strong, the court initiated jury selection through a process that had the practical effect of excluding the public, including the media, from voir dire. After Maine Today Media, Inc.'s request that the court open the voir dire process to the public was denied, Maine Today filed a motion to intervene, which the trial court denied. Maine Today filed an interlocutory appeal. The Supreme Court (1) vacated the denial of the motion to intervene and allowed intervention for the limited purpose of the matters addressed in this appeal; and (2) vacated the court's order barring the public from the entirety of the voir dire process. Remanded to the trial court to conduct the remaining voir dire in a presumptively public manner. View "State v. Strong" on Justia Law

After a jury trial, Defendant was found guilty of intentional or knowing murder for killing a sixteen-year-old girl, who was found buried with her wrists bound in duct tape, behind Defendant's mother's home. Defendant was sentenced to forty-seven years' incarceration. The Supreme Court affirmed. Defendant subsequently moved for additional DNA analysis and a new trial, claiming that a trace amount of male DNA previously found in a clipping from the duct tape had been further analyzed, and that Defendant was excluded as the source of that DNA. The post-conviction court denied Defendant's motion for a new trial, holding that the newly discovered DNA evidence did not make a different verdict probable due to the strong evidence of Defendant's guilt and the limited nature of the additional DNA test results. The Supreme Court affirmed, holding that the court did not err in its findings of fact, misapply the relevant statute, or abuse its discretion in denying the motion for a new trial. View "State v. Reese" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and criminal mischief. The Supreme Court affirmed, holding that the jury rationally could have found every element of the offenses beyond a reasonable doubt, as (1) the evidence presented was sufficient to support the jury's findings that Defendant obtained and intended to deprive the State of possession of property with a value greater than $1,000; and (2) the evidence was sufficient to support the jury's findings that Defendant intentionally, knowingly, or recklessly damaged or destroyed property of the State without reasonable grounds to do so. View "State v. Reed" on Justia Law

After a jury trial, Defendant was convicted for the intentional or knowing murder of his roommate. Defendant appealed, arguing that the trial court erred in concluding that he waived his Fifth Amendment privilege against self-incrimination and ordering him to answer a question posed by the State on cross-examination. The Supreme Court affirmed the conviction, holding that the trial court did not abuse its discretion (1) in determining that Defendant waived his Fifth Amendment privilege and in reasoning that the disputed question posed by the State was within the scope of his testimony on direct examination; and (2) in instructing the jurors that they could consider Defendant's unprivileged refusal to answer the State's question on cross-examination. View "State v. Butsitsi" on Justia Law