Justia Maine Supreme Court Opinion Summaries

Law enforcement in Maine received a tip from a confidential source about suspicious rental car activity by Calvin Vandine, who was known to use drugs and associate with traffickers. Officers tracked Vandine’s movements and, based on the tip and corroborating information, stopped his car, which was also occupied by Derric McLain. During the stop, officers found drugs and arrested both men. McLain was later identified as having outstanding warrants, including for drug trafficking. The stop lasted about twenty-eight minutes, and a subsequent search revealed significant quantities of controlled substances.Prior to trial in the Penobscot County Unified Criminal Docket, McLain moved to suppress evidence from the stop and statements made during custodial interrogation, arguing lack of reasonable suspicion for the prolonged detention and that he had not waived his privilege against self-incrimination. The trial court (Anderson, J.) denied the motion to suppress, finding the stop justified and the statements admissible. After a jury trial before Justice Murray, McLain was convicted of aggravated drug trafficking and violation of condition of release, receiving a substantial sentence.On appeal, the Maine Supreme Judicial Court reviewed the denial of the suppression motion. The Court affirmed the lower court’s findings that the stop, search, and arrest were supported by reasonable suspicion and were not unconstitutionally prolonged. However, the Court held that McLain did not clearly waive his privilege against self-incrimination under article I, section 6 of the Maine Constitution, as his responses during interrogation were ambiguous and officers failed to clarify his intent. The Court vacated the conviction and the suppression order in part, remanding for further proceedings, and established that a clear and unequivocal waiver is required before custodial interrogation may proceed in Maine. View "State v. McLain" on Justia Law

The defendant was convicted of two counts of unlawful sexual contact and one count of unlawful sexual touching involving his niece by marriage, who was a minor at the time. The incidents occurred in 2020 at the defendant’s home in West Gardiner, Maine, when the victim was left alone with him during family gatherings. The victim later disclosed the abuse in a forensic interview at a Children’s Advocacy Center (CAC), which was video recorded. The State charged the defendant in March 2022, and after a grand jury indictment, the case proceeded to trial. The defendant was subject to bail conditions restricting contact with minors.Prior to trial in the Kennebec County Unified Criminal Docket, the defendant moved for a bill of particulars and later asserted his right to a speedy trial, which he temporarily waived to obtain out-of-state records. He renewed his speedy trial demand, but delays occurred due to both his requests for specific trial dates and court scheduling constraints. The trial court denied his motion to dismiss for a speedy trial violation, finding that the delays were attributable to both parties and that the prejudice suffered was insufficient to warrant dismissal. The court also admitted the CAC video under 16 M.R.S. § 358, over the defendant’s objections based on confrontation and due process rights, and after editing out most references to uncharged conduct. The jury found the defendant guilty of the counts related to West Gardiner and not guilty of those related to Augusta.On appeal, the Maine Supreme Judicial Court reviewed the denial of the speedy trial motion, the admission of the CAC video, and the applicability of section 358. The Court held that there was no violation of the defendant’s speedy trial rights under either the Maine or United States Constitutions, that the admission of the CAC video did not violate the Maine Confrontation Clause or Due Process Clause, and that the amended version of section 358 applied to the case. The judgment of conviction was affirmed. View "State of Maine v. Engroff" on Justia Law

In 2023, the Maine Legislature enacted the Paid Family and Medical Leave (PFML) program, requiring employers to remit quarterly premiums into a state fund beginning January 1, 2025. The program allows covered individuals to take up to twelve weeks of leave for qualifying reasons, with benefits paid from the fund. Employers may apply to substitute an approved private plan that provides substantially equivalent benefits, which exempts them from further premium payments. The Maine Department of Labor adopted rules implementing the PFML program, including a provision that all employers must pay nonrefundable premiums for the first quarter of 2025, even if they later obtain approval for a private plan. Employers could begin applying for private plan approval after April 1, 2025, due to the time needed for insurers to develop compliant policies.The Maine State Chamber of Commerce and Bath Iron Works challenged the Department’s rule requiring nonrefundable premiums, arguing it conflicted with the PFML Act and constituted an unconstitutional taking under both the Maine and U.S. Constitutions. The Kennebec County Superior Court accepted a consented-to motion to report three legal questions to the Maine Supreme Judicial Court: whether the rule conflicted with the Act or was arbitrary and capricious, and whether it constituted a taking under state or federal law.The Maine Supreme Judicial Court accepted the report and held that the Department’s rules do not conflict with the PFML Act and are not arbitrary, capricious, or otherwise unlawful. The Court found that the statute unambiguously requires employers to remit premiums until a private plan is approved, and the rules reasonably implement the legislative intent. Additionally, the Court determined that the obligation to pay premiums does not constitute a cognizable taking of private property under either the Maine or U.S. Constitution. The Court answered all three reported questions in the negative and remanded the case for further proceedings. View "Maine State Chamber of Commerce v. Department of Labor" on Justia Law

The defendant was convicted after a bench trial of several offenses, including attempted murder, domestic violence aggravated assault, domestic violence criminal threatening, assault on an officer, and violating a condition of release. The convictions arose from an incident in which the defendant, following a period of repeated contact with his former partner, attacked her in a hotel parking lot. The attack involved strangulation, threats to kill, and physical violence, resulting in significant injuries to the victim. Bystanders, including a hotel clerk and a van driver, intervened, and police officers ultimately subdued and arrested the defendant after a struggle in which an officer was bitten and his firearm was nearly taken.The Kennebec County Unified Criminal Docket (Murphy, J.) found the defendant guilty of the charged offenses. At sentencing, the court imposed a thirty-year sentence for attempted murder, with all but eighteen years suspended and four years of probation, and additional sentences for the other convictions. In determining the sentence for attempted murder, the court considered the brutality and persistence of the attack as aggravating factors, as well as the defendant’s lack of criminal history and acceptance of responsibility as mitigating factors. The court declined to treat the defendant’s “blind jealous rage” as a mitigating factor, finding it was not a biologically based mental illness.On appeal, the Maine Supreme Judicial Court reviewed two arguments: that the trial court violated the Eighth Amendment by not considering the defendant’s “blind rage” as a mitigating factor, and that the court erred in finding as an aggravating factor that the defendant assaulted the hotel clerk. The Supreme Judicial Court held that the Eighth Amendment does not require a sentencing court in a noncapital case to consider unprovoked “blind rage” as a mitigating factor. However, the Court found plain error in the trial court’s reliance on an unsupported finding that the defendant assaulted the hotel clerk as an aggravating factor. The judgment of sentence for attempted murder was vacated and the case remanded for resentencing. View "State of Maine v. Goncalves" on Justia Law

Kyle M. Fitzgerald was stopped by Maine State Police on Interstate 295 for not wearing a seatbelt and driving significantly below the speed limit. During the stop, Fitzgerald and her passengers gave inconsistent and confusing answers about their destination and how long they had known each other. One passenger was particularly anxious, another was standoffish, and a third pretended to be asleep. The police officer, Trooper Young, requested a drug detection dog, which arrived seventy-seven minutes after the stop began. The dog indicated the presence of drugs, leading to a search that uncovered a substantial quantity of illegal drugs.The trial court (Cumberland County) granted Fitzgerald’s motion to suppress the evidence obtained from the search, finding that the officers lacked probable cause. The court determined that the reasonable suspicion justifying the initial stop had been resolved well before the dog arrived, and there was no reasonable suspicion of illegal drug activity to justify prolonging the detention.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the duration of Fitzgerald’s detention exceeded the constitutional limit once the officer confirmed the identity of one of the passengers, which was thirty-four minutes before the drug detection dog arrived. The court concluded that the officer’s suspicion of illegal drug activity was based on a general hunch rather than an articulable and objectively reasonable suspicion. Therefore, the prolonged detention violated the Fourth Amendment, and the evidence obtained from the search was rightly suppressed. View "State v. Fitzgerald" on Justia Law

Townsend Thorndike was convicted of unlawful sexual contact and visual sexual aggression against a child. The charges stemmed from alleged sexual abuse that occurred in the summer of 2021 when the victim was six years old. The State sought to admit a video recording of the victim’s forensic interview under a statutory hearsay exception. Thorndike argued that the statute allowing the video’s admission was unconstitutionally enacted as emergency legislation and violated the separation of powers clause in the Maine Constitution.The trial court initially granted the State’s motion to admit the video but later vacated its order, concluding the statute did not apply retroactively to pending cases. The State then sought and obtained an emergency legislative amendment clarifying the statute’s retroactive applicability. The trial court reinstated its original order, allowing the video’s admission. Thorndike was subsequently convicted on all counts, and the court sentenced him to fourteen years of imprisonment with all but eight years suspended, plus six years of probation.The Maine Supreme Judicial Court reviewed the case and upheld the trial court’s decision. The Court found that the emergency enactment of the statutory amendment was constitutionally valid, as the preamble expressed sufficient facts to constitute an emergency. The Court also determined that the legislative action did not violate the separation of powers doctrine, as it did not mandate the admission of evidence but clarified the statute’s applicability to pending cases. The Court affirmed Thorndike’s conviction and the trial court’s admission of the forensic interview video. View "State of Maine v. Thorndike" on Justia Law

Rochelle Gleason was convicted of aggravated trafficking of a scheduled drug that caused the death of a person. In October 2021, Gleason communicated with the decedent about purchasing fentanyl and heroin. On October 16, 2021, the decedent bought drugs from Gleason, consumed them, and died of acute intoxication from fentanyl and kratom. The Maine Office of the Chief Medical Examiner sent a blood sample to a lab, where several employees conducted tests. A forensic toxicologist, Chelsea Deisher, reviewed the data and documentation and developed a toxicology report indicating the presence of fentanyl and kratom in the decedent’s blood.The State charged Gleason on September 28, 2022, and she pleaded not guilty. During the trial, Deisher testified about the test results, although she did not conduct the tests herself. Gleason objected, arguing that her Sixth Amendment right to confront the witnesses against her was violated because she could not cross-examine the actual testers. The trial court allowed Deisher’s testimony, and the jury found Gleason guilty. She was sentenced to eighteen years in prison, with all but eight years suspended, and four years of probation. Gleason appealed the conviction.The Maine Supreme Judicial Court reviewed the case, focusing on the Confrontation Clause issue. The court noted that the U.S. Supreme Court’s decision in Smith v. Arizona, issued during the appeal, rejected the rationale that allowed experts to testify based on out-of-court statements not admitted for their truth. The court found that Deisher’s testimony relied on the truth of the data and documentation generated by others, which Gleason could not cross-examine. The court vacated the judgment and remanded the case for a new trial to determine whether the statements relied upon by Deisher were testimonial. View "State of Maine v. Gleason" on Justia Law

Marc A. Lesperance was found with his dog off-leash in Baxter Woods, Portland, despite a city ordinance requiring dogs to be leashed from April 1 to July 31. A park ranger informed Lesperance of the rule, but Lesperance refused to comply. The ranger, after consulting with a colleague, issued a summons and complaint. The District Court (Portland) fined Lesperance $500, noting it was not his first violation of the ordinance.Lesperance appealed, arguing that the park ranger was not authorized to issue the summons and complaint. He also claimed the city ordinance was preempted by state law and unconstitutionally vague. The court found these arguments without merit, stating the ordinance was clear and not preempted by state law.The Maine Supreme Judicial Court reviewed the case. The court considered whether the park ranger, appointed as a constable, needed to meet specific training requirements to enforce the ordinance. The Attorney General, representing the Maine Criminal Justice Academy, suggested that constables might require less rigorous training than law enforcement officers. The court applied the "de facto officer" doctrine, concluding that Lesperance could not challenge the ranger's authority based on potential training deficiencies. The court affirmed the judgment, validating the ranger's actions as those of a de facto officer. View "City of Portland v. Lesperance" on Justia Law

Clifton Thomas was convicted of two counts of aggravated trafficking of scheduled drugs and one count of criminal forfeiture of property. The charges stemmed from a search of an apartment where Thomas was staying, which uncovered drugs, drug paraphernalia, and a firearm. The search was conducted pursuant to a warrant obtained after Thomas was involved in a domestic violence incident. Thomas challenged the search, arguing that the warrant lacked probable cause for drug-related items and that the evidence was not in plain view.The trial court denied Thomas's motions to suppress the evidence, finding that the search warrant was valid for firearms and a cell phone, and that the drugs were discovered in plain view during a lawful search. The court also denied Thomas's discovery motions regarding missing surveillance video, cell phones, and a coat, concluding that the State did not act in bad faith and that the evidence did not have apparent exculpatory value. Additionally, the court allowed a new chemist to testify about the drug analysis, despite the original chemist not testifying.The Maine Supreme Judicial Court reviewed the case and found that Thomas's confrontation rights were violated by the admission of the new chemist's testimony, which relied on the original chemist's notes and data. The court determined that this violation was not harmless, as the chemist's testimony was crucial to establishing the weight of the drugs, a key element of the charges. Consequently, the court vacated Thomas's conviction and remanded the case for further proceedings. View "State of Maine v. Thomas" on Justia Law

Calixte Fleury was convicted of aggravated trafficking, unlawful trafficking, unlawful possession of scheduled drugs, and operating under the influence. On September 18, 2020, Fleury was driving on I-95 when he crashed his vehicle. A responding sergeant found Fleury with a bag of pills containing fentanyl and tramadol, and later discovered more fentanyl and cash on Fleury. Fleury's blood alcohol content was 0.093 grams per 100 milliliters. He was indicted and later charged with multiple counts, including aggravated trafficking and unlawful trafficking of scheduled drugs.The trial court (York County, Martemucci, J.) held a jury trial, resulting in guilty verdicts on all four criminal counts. The court found in favor of Fleury on the criminal forfeiture count. Fleury was sentenced to seven years with all but four years suspended for aggravated trafficking, three years for unlawful trafficking, and 30 days for operating under the influence, with some sentences running concurrently. The court merged the unlawful possession count with the unlawful trafficking count.The Maine Supreme Judicial Court reviewed the case. Fleury argued that the application of a repealed definition of "traffick" was unconstitutional. The court disagreed, stating that the repealed statute was rationally related to controlling opioids and its application was not unconstitutional. The court also noted that the amended statute did not apply retroactively to Fleury's case.However, the court found that the trial court should have merged the aggravated trafficking count with the unlawful trafficking and possession counts for sentencing. The Maine Supreme Judicial Court vacated the sentence and remanded for resentencing, affirming the convictions in all other respects. View "State of Maine v. Fleury" on Justia Law