Articles Posted in Constitutional Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv), holding that Father failed to present a prima facie case of ineffective assistance of counsel and that the record evidence supported the court’s findings and discretionary determinations. On appeal, Father argued that his counsel’s withdrawal two months before the termination hearing amounted to ineffective assistance of counsel. The Supreme Judicial Court disagreed, holding that Father did not demonstrate prejudice from counsel’s performance. View "In re Child of Stephen E." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of assault, holding that Defendant was not denied a fair trial because one of the jurors reported that she had felt pressured to return a guilty verdict. After the court informed the parties of the juror’s statement and invited the parties to be heard, the court concluded that there was no evidence of juror misconduct and that the guilty verdict would stand. The Supreme Judicial Court held that Defendant was not deprived of a fair trial because there was no evidence of outside influence, bias, or misconduct, and therefore, the juror’s statement that she felt pressured to return a guilty verdict fell within the categories of evidence prohibited from use by Me. R. Evid. 606(b)(1). View "State v. Leon" on Justia Law

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The Supreme Judicial Court affirmed the judgment of conviction entered by the sentencing court following Defendant’s guilty plea to an information charging him with felony murder. The sentencing court imposed a prison sentence of twenty years, all but ten years suspended, with four years’ probation and a restitution order. On appeal, Defendant argued that his sentence was unconstitutionally disproportionate and denied his constitutional right to equal protection. The Supreme Judicial Court disagreed, holding (1) Defendant’s offense and sentence did not generate an “inference of gross disproportionality”; and (2) notwithstanding the fact that Defendant’s codefendant received only a seven-year sentence, Defendant’s sentence did not violate Defendant’s equal protection rights. View "State v. Lopez" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of arson. On appeal, Defendant argued that the trial court violated his right to be protected against double jeopardy by admitting in his trial evidence on which the State relied to try to prove some of the charges of which Defendant was acquitted in a prior trial. The Supreme Judicial Court agreed, holding that the admission of that evidence was barred by collateral estoppel and violated Defendant’s right to be protected from double jeopardy and that the error was not harmless. View "State v. Weckerly" on Justia Law

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The Supreme Judicial Court affirmed the trial court’s judgment convicting Defendant of three counts of possession of sexually explicit material, thus denying Defendant’s challenges to the denial of his motion to suppress statements and digital evidence obtained by the police after they entered his home. On appeal, Defendant argued that the trial court erred in finding that he consented to the police officers’ entry into his home, which resulted in the search and seizure of his computer. The Supreme Judicial Court held that there was sufficient evidence in the record to support a finding that Defendant consented to the officers’ entry. View "State v. Marquis" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated trafficking in scheduled drugs, unlawful possession of a scheduled drug, and unlawful possession of oxycodone. On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence that was found in the curtilage of his home and abused its discretion in denying his motion to exclude other evidence on the basis of a discovery violation. The Supreme Court disagreed, holding (1) the evidence obtained as a result of law enforcement officers’ search of bags they discovered within Defendant’s “curtilage” was properly admitted under the plain view exception and the inevitable discovery exception to the warrant requirement; and (2) the court did not err in denying Defendant’s motion to exclude the testimony of a pharmacist because the State had only recently notified Defendant that the pharmacist would testify in the place of another pharmacist who had also been on the witness list. View "State v. Sullivan" on Justia Law

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The Town of Steuben’s taking of an interest in Rogers Point Road by eminent domain pursuant to Me. Rev. Stat. 23, 3023 was constitutional because it arose from a public exigency and was for public use. Bayberry Cove Children’s Land Trust filed a complaint challenging the Town’s determinations that the taking of an interest in the road was supported by a public exigency and that the use of the road was public. The superior court affirmed the Town’s decision. The Supreme Judicial Court affirmed, holding (1) there was a rational basis in the record to support the Town’s finding of a public exigency; (2) evidence in the record, confirmed by the Trust’s characterization of the public’s right to use the road, definitively established that the interest in the road was taken for a public use; and (3) therefore, the taking was constitutional. View "Bayberry Cove Children's Land Trust v. Town of Steuben" on Justia Law

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The motion court did not err by applying the inevitable discovery doctrine to deny Defendant's motion to suppress evidence of drugs found on his person before the issuance of a search warrant. The Unified Criminal Docket found Defendant guilty of unlawful trafficking in scheduled drugs and ordering a criminal forfeiture. In denying Defendant’s motion to suppress drug evidence, the trial court found that law enforcement officers’ warrantless entry into an apartment was not justified by exigent circumstances but that it was highly likely that the officers inevitably would have discovered drugs. The Supreme Court affirmed the denial of the motion to suppress, holding (1) the motion court did not err by finding that the police inevitably would have discovered the drug evidence at issue by lawful means; and (2) application of the inevitable discovery doctrine does not create an incentive for police misconduct and does not significantly weaken Fourth Amendment protections. View "State v. Prinkleton" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the district court, entered after a jury trial, finding that Defendant had committed the civil violations of improperly displaying a registration plate and failing to register a vehicle that is operated or remains on a public way. Contrary to Defendant’s arguments on appeal, the Supreme Court held (1) the district court did not err in finding that the State established the elements of each violation; and (2) the court proceedings below did not violate the Due Process Clause, the Equal Protection Clause, or the Americans with Disabilities Act. View "State v. Chase" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court granting the Department of Environmental Protection’s request for a permanent injunction prohibiting Dubois Livestock, Inc. and the Randrick Trust (collectively, Appellants) from denying the Department access for solid waste inspections. The court held (1) the superior court did not err in concluding that Me. Rev. Stat. 38, 347-C and 1304(4-A) permit the Department to enter Appellants’ property without consent or an administrative search warrant; and (2) the warrantless searches authorized by these statutes do not violate Appellants’ constitutional right to be free from unreasonable searches and seizures. View "State v. Dubois Livestock, Inc." on Justia Law