Justia Maine Supreme Court Opinion Summaries

Chad Gurney was convicted of murder and arson following a jury-waived trial. The Supreme Court affirmed the judgment of the trial court, holding that the court did not err in (1) denying Gurney's motions to suppress evidence found on his Facebook account, laptop computer, and cell phone; (2) admitting evidence of a reference to a beheading video found in unallocated space on the hard drive of Gurney's laptop computer; (3) not addressing in its findings the journals and emails that Gurney offered as evidence of his preexisting and ongoing psychosis; and (4) finding that Gurney did not carry his burden of proving that he suffered from a mental disease or defect that substantially affected his ability to appreciate the wrongfulness of his conduct. View "State v. Gurney" on Justia Law

Mallory McPartland appealed from a judgment of conviction entered in the criminal docket upon her conditional guilty plea to operating under the influence (OUI) following the denial of her motion to suppress evidence. McPartland argued that the suppression court erred in concluding that the police officer she encountered at an OUI roadblock had a reasonable articulable suspicion of impairment that was sufficient to justify additional sobriety screening. The Supreme Court affirmed the suppression court's finding that the officer had reasonable suspicion to refer McPartland to secondary screening in this case, holding that the court correctly concluded that satisfaction of the reasonable articulable suspicion standard justifies directing a motorist to secondary screening following an initial roadblock stop. View "State v. McPartland" on Justia Law

After a jury trial, Kenny Ouellette was convicted of reckless conduct. Ouellette appealed, arguing that the superior court erred in (1) declining to instruct the jury on his justification of self-defense to the charge of reckless conduct, and (2) failing to inform the jury of the parties' out-of-course resolution that resulted in a dismissal of a count of criminal mischief stemming from the same incident. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's instruction to the jury that it could not consider self-defense as to the charge of reckless conduct was erroneous, and (2) the error was not harmless. Remanded for a new trial. View "State v. Ouellette" on Justia Law

Following a jury trial, Jesse Guyette was convicted of unlawful possession of scheduled drugs. Guyette appealed, arguing that the superior court erred by admitting several statements at trial pursuant to the Me. R. Evid. 804(b)(3) exception to the hearsay rule for statements against penal interest. The Supreme Court vacated Guyette's conviction, holding (1) the trial court abused its discretion by admitting the out-of-court statements of a person who was not a codefendant at trial but whose statements implicated Guyette because the statements did not fall within the Rule 804(b)(3) hearsay exception; and (2) the court's error in admitting those statements was not harmless. View "State v. Guyette" on Justia Law

Raymond Cloutier appealed from a judgment entered in the district court granting Robin Turner's motion to enforce the child support provisions of a 1992 amended divorce judgment. The Supreme Court affirmed the judgment, holding (1) Turner had standing to bring the motion even though the children were above the ages of eighteen because, although the obligation to provide future support ends when the child reaches majority, liability for arrearages does not terminate then; (2) where child-support arrearages are considered money judgments and there is no statute of limitations for money judgments, Turner's claim of overdue child support was not time-barred; (3) the court's failure to apply the statute of limitations did not deprive Cloutier of his constitutional right of equal protection because Cloutier was not treated any differently than fathers who are subject to child support enforcement stemming from a paternity action; and (4) Cloutier failed to make the showing necessary to establish the defense of laches. View "Cloutier v. Turner" on Justia Law

Defendant was indicted for aggravated trafficking of scheduled drugs, unlawful trafficking in scheduled drugs, and illegal importation of scheduled drugs. Defendant moved to suppress incriminating statements he made to a Maine Drug Enforcement Agency (MDEA) agent while in the agent's custody and after Defendant had invoked his right to counsel in violation of the Fifth Amendment. The superior court granted Defendant's motion after applying Maryland v. Shatzer, concluding that the State had failed to prove that Defendant's waiver of his right to counsel was voluntary because the agent had resumed his questioning of Defendant just a few hours after Defendant had invoked his right to counsel, far less than the fourteen-day standard required by Shatzer. The Supreme Court vacated the superior court, holding that the court erred by evaluating the evidence and rendering its findings through the lens of the Shatzer fourteen-day standard and should have employed the analytical framework advanced in Edwards v. Arizona and Oregon v. Bradshaw in determining whether Defendant voluntarily reinitiated interrogation. Remanded for the court to reconsider the evidentiary record and to apply the Edwards and Bradshaw standards. View "State v. Knowlton" on Justia Law

Following a jury trial, Rory Holland was convicted of two counts of intentional or knowing murder and sentenced to two concurrent life sentences. The Supreme Court affirmed the judgment and sentences, holding (1) the trial court did not abuse its discretion when it refused to admit evidence of the victims' reputations for violence that was not known to Holland prior to the murders; (2) the trial court did not err in admitting a book containing the Maine Criminal Code into evidence where the evidence was not unfairly prejudicial; (3) the trial court properly denied Holland's motion in limine to permit statements from an earlier civil trial to be admitted into evidence to provide context for Holland's reaction to threats and violence; (4) there was sufficient evidence to disprove Holland's claim of self-defense; (5) the trial court did not err by allowing the State to reopen its case to present evidence regarding identification of Holland; and (6) the court did not abuse its discretion in imposing concurrent life sentences. View "State v. Holland" on Justia Law

While Shawn Sayer was incarcerated, the district court granted a final order for protection from abuse to Liv Morrison. Sayer appealed, asserting, inter alia, that he was deprived of due process by not being given the opportunity to be present at or participate in the hearing. The Supreme Court vacated the judgment of the district court, holding that Sayer's incarceration and the need to protect his rights by facilitating his participation in the hearing, either in person or by a remote video or audio connection, demonstrated good cause to either make an accommodation to allow him to participate in the hearing or grant a short continuance of the hearing to allow his participation on another date. Remanded. View "Morrison v. Sayer" on Justia Law

After a jury trial, Daniel Fortune was found guilty on eleven counts related to the attempted murder of a five-member family in their home. The Supreme Court affirmed the convictions and resulting sentences, holding (1) the trial court did not err when it instructed the jury that it could find Fortune guilty of attempted murder if the jury found that the State had proved attempted murder as to one of three victims named in a single count of the indictment; (2) the evidence was sufficient to support Fortune's convictions of the aggravated attempted murders of two of the victims; (3) the aggravated murder statute does not violate the state or federal Constitution; (4) the sentencing court did not err in its application of the sentencing analysis, resulting in the imposition of concurrent life sentences for two counts of aggravated attempted murder, and the court did not err concluding that a split sentence was not available to Fortune; and (5) the fact that the sentencing court did not clearly articulate on the record the three-step sentencing analysis in determining the concurrent sentences imposed on the remaining nine felony counts was harmless, assuming it was error at all. View "State v. Fortune" on Justia Law

After a jury trial, Defendant David Churchill was found guilty of one count of unlawful sexual contact. Defendant appealed, arguing that the trial court erred by admitting in evidence a printout of an online chat between Defendant and the victim, a twelve-year-old girl, because the printout was not authenticated pursuant to Me. R. Evid. 901(a). The Supreme Court affirmed, holding (1) the trial court properly concluded that testimony of a police detective was sufficient to authenticate the chat log, and (2) other evidence established that Defendant was the person with whom the victim was chatting, so no greater showing was required. View "State v. Churchill" on Justia Law