Justia Maine Supreme Court Opinion Summaries

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

Defendant was convicted for aggravated trafficking in scheduled drugs. The superior court denied Defendant's motion for a new trial. Defendant appealed, arguing that he was entitled to a new trial because he was denied effective assistance of counsel when his attorney failed to advise him of the immigration consequences of his guilty plea. The Supreme Court affirmed, holding (1) the trial court properly denied Defendant's motion for a new trial because post-conviction review was the exclusive avenue for judicial review of an ineffective assistance of counsel claim; and (2) because Defendant did not avail himself of the post-conviction review process, the Court could not decide if, in light of the Supreme Court's decision in Padilla v. Kentucky, the post-conviction review procedure was unconstitutional as applied to Defendant's circumstances. View "State v. Ali" on Justia Law

Employee brought an employment discrimination claim against Employer pursuant to the Maine Human Rights Act, alleging that Employer discriminated against him based on his sexual orientation. A jury entered a verdict for Employee and awarded Employee compensatory and punitive damages. Employer appealed, arguing, among other things, that it was entitled to judgment as a matter of law on liability. The Supreme Court affirmed, holding (1) the record contained sufficient evidence to support the jury's finding that actions of Employer made it futile for Employee to apply for a promotion, and thus, Employee's failure to apply for the position fell under the futility exception to the rule that an individual must apply for a position before he can claim he was denied that position; (2) the court applied the proper statutory cap to the jury's award; and (3) the trial court did not abuse its discretion in denying Employer's motion for a new trial or remittitur of damages. View "Russell v. ExpressJet Airlines" on Justia Law

After a jury trial, Appellant Scott Brockelbank was convicted of aggravated criminal trespass and assault. The Court of Appeals affirmed Appellant's judgment and sentence, holding (1) the evidence was sufficient to disprove Appellant's competing harms defense because there was sufficient evidence for the jury to find that the State disproved at least one of the elements of the defense; and (2) the sentencing court acted within its discretion by permitting the State to introduce information related to Appellant's nonpublic juvenile adjudication during the sentencing proceedings to the limited extent reasonably necessary to respond to and explain information introduced by Appellant related to the same adjudication. View "State v. Brockelbank" on Justia Law

After a jury trial, Luis Pabon was convicted of elevated aggravated assault and attempted murder for the stabbing of his girlfriend and housemate at the time. Pabon's defense was partially built around the claim that he was so intoxicated that he had stabbed the victim in self-defense. On appeal, Pabon contended that the trial court erred by failing to include a dwelling-place exception to the duty to retreat in its self-defense instruction to the jury. The Supreme Court affirmed the judgment of conviction, holding that the court's omission of the dwelling-place exception from its self-defense instruction was not obvious error. View "State v. Pabon" on Justia Law

Defendant Ryan Preston was found guilty of criminal threatening with a dangerous weapon. On appeal, Preston argued (1) that the statutory provisions defining deadly force and discussing defense of premises were unconstitutionally vague, and (2) the trial court did not adequately instruct the jury on the charge of criminal threatening with a dangerous weapon. The Supreme Court affirmed the judgment of the trial court, holding (1) the definition of deadly force was not unconstitutionally vague as it interacted with the definition of defense of premises in this case, and (2) the trial court's jury instructions did not constitute obvious error. View "State v. Preston" on Justia Law

Timothy Burns was convicted of theft of unauthorized taking, a Class C offense, following a jury trial. The Supreme Court affirmed the conviction and sentence, holding (1) because the jury could not have rationally found from the evidence that Burns was guilty of theft of property with a value of less than $1000 and because a theft by unauthorized taking is a Class C offense when the property stolen is valued between $1000 and $10,000, the court's failure to instruct the jury concerning the amount necessary to elevate a theft to a Class C offense was harmless; (2) the evidence was sufficient to establish Burns' guilt beyond a reasonable doubt because the jury rationally could have found from the evidence presented at trial that Burns was guilty of the theft of the check involved in this case, and the jury could only have found that the amount stolen was the amount of the check; and (3) the superior court did not err by sentencing Burns to twenty-two months' incarceration. View "State v. Burns" on Justia Law

While on patrol, a state police trooper clocked a Pontiac traveling at a speed well above the speed limit. As the trooper was making a turn to pursue the car, a motorcycle driven by Ronald LaPlante passed him. The trooper lost sight of the car but did come upon the motorcycle. The trooper stopped LaPlante for the sole purpose of asking about the direction of the Pontiac but obtained sufficient for the State to charge LaPlante with criminal operating under the influence. LaPlante moved to suppress the evidence obtained during the vehicle stop, but the superior court denied the motion. LaPlante was then convicted of operating under the influence. On appeal, the Supreme Court vacated the judgment, holding (1) a law enforcement officer's investigation of a third party's civil speeding offense does not justify the discretionary seizure of a motorist in the absence of reasonable articulable suspicion, and (2) the superior court erred when it denied LaPlante's motion to suppress. Remanded. View "State v. LaPlante" on Justia Law

After pleading guilty to criminal charges, Terry Chesnel received judgments of conviction requiring him to pay $3700 in court fines. Soon after Chesnel was incarcerated, the Department of Corrections began withdrawing twenty-five percent of all funds deposited into Chesnel's prison account to satisfy his court fines. Chesnel later filed a petition for post-conviction review, asserting that he had been denied effective assistance of counsel. His petition did not mention the Department's collection of funds from his prison account. The superior court denied Chesnel's petition, and no appeal was taken. Two years later, Chesnel filed a motion to modify the conditions governing the collection of his court fines while he was in prison. The superior court denied the motion. Chesnel appealed, contending, inter alia, that the Department's collection of funds without notice or hearing was an unconstitutional taking and violation of due process. The Supreme Court dismissed the appeal, holding that because Chesnel did not raise the issue through a petition for post-conviction review, the superior court did not have jurisdiction to entertain Chesnel's motion. Remanded to the superior court for a dismissal of the motion. View "State v. Chesnel" on Justia Law

Kaihlil Nigro was convicted of two counts of aggravated trafficking of scheduled drugs with an accompanying order for criminal forfeiture following a jury trial. Nigro appealed, contending that he was deprived of a fair trial because the court did not ask prospective jurors whether they harbored prejudice or bias against members of the Islamic faith. Nigro also argued that the court erred in refusing to suppress (1) an out-of-court photographic identification made by a confidential informant, (2) evidence obtained during the execution of a search warrant, and (3) documents seized during his arrest. The Supreme Court affirmed, holding (1) Nigro did not establish that the court committed obvious error in conducting voir dire, (2) the informant's identifications were properly admitted at trial despite an unnecessarily suggestive identification procedure, (3) the search warrant affidavit sufficiently established probable cause, and thus the evidence obtained during the execution of the search warrant was properly admitted, and (4) the documents seized during Nigro's lawful arrest were properly admitted. View "State v. Nigro" on Justia Law