Justia Maine Supreme Court Opinion Summaries

Following a jury trial, Darlene George was convicted of intentional or knowing murder and conspiracy to commit murder. The Supreme Court affirmed the judgment, holding (1) the circuit court did not err in denying George's motion to suppress her grand jury testimony, as the use of the testimony at trial did not violate George's right against compulsory self-incrimination and the testimony was voluntary; (2) the court did not err in denying George's co-defendant's motion to sever the trial; (3) the indictment was sufficient; (4) the evidence was sufficient to support George's convictions; and (5) George's conviction was fundamentally fair and did not violate due process. View "State v. George " on Justia Law

Following a jury trial, Kirk Gould was convicted of gross sexual assault (Class A) and gross sexual assault (Class B). Gould appealed. The Supreme Court affirmed, holding (1) the trial court properly denied Gould's motion to suppress his confession as involuntary where the totality of the circumstances demonstrated that Gould's confession was voluntary; (2) Gould was not denied a fair trial based on the prosecutor's alleged misrepresentation of the evidence in closing argument because the prosecutor did not engage in misconduct; and (3) the trial court did not err by denying Gould's motions for a new trial and sanctions based on an alleged discovery violation. View "State v. Gould" on Justia Law

Jack Bailey appealed from a judgment of conviction of ten counts of gross sexual assault and two counts of unlawful sexual conduct entered in the superior court, arguing that the court erred in denying his motion to suppress live-witness testimony because the testimony should have been suppressed as fruit of the poisonous tree in violation of the Fourth Amendment. The State contended that the court erred in granting Bailey's motion to suppress evidence discovered during a police search of Bailey's residence. The Supreme Court affirmed the judgment, holding (1) the circuit court correctly found that Bailey's consent to the search of his apartment was not voluntary, and therefore, the evidence found during the search was properly suppressed; and (2) the circuit court did not err in denying the motion to suppress the live-witness testimony after considering the factors set out in United States v. Ceccolini in determining the admissibility of the witnesses' testimony. View "State v. Bailey" on Justia Law

After a jury-waived trial, David Christian was convicted of three counts of theft by unauthorized taking, a Class D theft, and one count of theft by unauthorized taking, a Class E theft. Christian appealed, contending that the evidence was insufficient to establish beyond a reasonable doubt that he intended to deprive his employer of rent payments and that the court erred by classifying two counts as Class D theft rather than Class E theft. The Supreme Court vacated and modified the judgment, holding (1) the record contained sufficient evidence to support the court's findings regarding Christian's intent; but (2) the court erred in its classification of the contested counts. Remanded for resentencing. View "State v. Christian" on Justia Law

MacImage of Maine and its principal asked six Maine counties to provide to them, in a specified digital format, copies of every document contained in the counties' registries of deeds, including the indexes to the recorded documents. The counties agreed to provide electronic copies of the registries' recorded documents, but disputes over the fees that the counties could charge for the requested electronic information precipitated this litigation. The superior court determined that the counties could not charge the fees that they proposed in their responses to the requests. The Supreme Court vacated the judgment of the superior court, which entered its judgment before recent legislation was passed. The Court held that the recent legislation was applicable to the dispute and that the responses of all but two of the six counties agreeing to provide the requested records in bulk and setting the costs for transferring the data fell within the law's parameters for reasonable fees. Remanded for entry of judgment in favor of those four counties and for further proceedings regarding the remaining two counties. View "MacImage of Me., LLC v. Androscoggin County" on Justia Law

Defendant Frank Johnson was convicted for operating after habitual offender revocation. Johnson appealed, arguing that the superior court erred in denying his motion to strike an earlier conviction offered by the State to enhance his current charge to a Class C crime because the prior conviction resulted from a guilty plea that was allegedly constitutionally flawed. At issue was whether Johnson had the right to collaterally attack the prior conviction. The Supreme Court affirmed after examining relevant federal and state precedent, holding (1) a criminal defendant may not collaterally attack a prior conviction during proceedings related to a different offense unless the defendant alleges a violation of the Sixth Amendment right to counsel; and (2) because Johnson did not assert a violation of his Sixth Amendment right to counsel as the basis for his collateral attack on his prior conviction, his motion to strike was properly denied without further hearing. View "State v. Johnson" on Justia Law

Defendant William Hanaman was convicted of intentional or knowing murder following a jury trial. Hanaman appealed, contending that the trial court erred in refusing to instruct the jury on the affirmative defense of adequate provocation to reduce the murder charge to manslaughter pursuant to Me. Rev. Stat. 17-A, 201(3). The trial court determined that an adequate provocation instruction was subsumed by instructions that were given on self-defense and imperfect self-defense. The Supreme Court affirmed, holding that the evidence was not legally sufficient to support a jury instruction on the affirmative defense of adequate provocation, and therefore, the court did not err in refusing to give an adequate provocation instruction in this case. View "State v. Hanaman" on Justia Law

Following a bench trial in the district court, Defendant John Maynard was convicted of operating while his license was suspended, with a prior conviction (OAS). Maynard appealed, arguing that the Secretary of State's certification of the notice of Maynard's suspension failed to prove the notice element of the OAS charge. The Supreme Court vacated the judgment of the district court, holding that the Secretary of State's certification on its face was inadequate to prove that the court provided Maynard notice of his license suspension, as a Secretary of State's certification that does not set forth any underlying facts pertaining to the notice of suspension does not suffice as proof of notice. View "State v. Maynard" on Justia Law

Timothy Robbins entered a conditional plea of guilty to and was convicted of operating under the influence (OUI), with two prior convictions, and operating after suspension. Robbins appealed, contending that the trial court erred in denying his motion to strike two prior uncounseled misdemeanor OUI convictions, which reflected that he appeared pro se but were silent as to the procedures taken to ensure that his constitutional right to counsel was satisfied. The Supreme Court affirmed the judgment of conviction, holding that Robbins could not prevail on the record because, as no evidence was presented to the contrary, the Court presumed the regularity that attaches to the final judgment of a conviction. View "State v. Robbins" on Justia Law

Following a nonjury trial, James Soucy was convicted of operating a motor vehicle under the influence of intoxicants (OUI) with one previous OUI conviction within a ten-year period. Soucy appealed, arguing that the evidence of impairment from his use of prescription drugs was insufficient to convict him of OUI. The Supreme Court affirmed, holding that because there was sufficient evidence in the record for the district court to find, beyond a reasonable doubt, that, while operating his motor vehicle, Soucy was impaired, to some extent, by his consumption of prescription drugs, the district court did not err in its judgment. View "State v. Soucy" on Justia Law