Articles Posted in Constitutional Law

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The Supreme Judicial Court affirmed orders of the trial court denying Appellant’s motions to suppress evidence that was seized by the local police department and state police and then returned to the individuals who reported the items stolen, holding that Appellant received a fair trial and that the search warrants were valid. On appeal, Appellant argued that the State failed to preserve exculpatory evidence in violation of his due process right to a fair trial, and that two search warrants failed to designate all of the items to be seized with adequate particularity, making the warrants unconstitutionally vague. The Supreme Judicial Court affirmed, holding (1) even if Appellant made the threshold showing that the evidence at issue was lost or destroyed, he did not demonstrate that any of the evidence had apparent exculpatory value at the time the items were returned to their owners; and (2) the search warrants identified the items to be seized with as much particularity as was possible under the circumstances. View "State v. Winchester" on Justia Law

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The Supreme Judicial Court vacated the judgment of the superior court dismissing as untimely Appellant’s petition seeking review of a rule promulgated by the Department of Corrections (DOC), holding that the court should have treated Appellant’s petition as a complaint for declaratory judgment and allowed him to amend his petition to that effect. In his petition, Appellant, a prisoner at the Maine State Prison, claimed that the DOC had promulgated and enforced a rule that violated Me. Rev. Stat. 34-A, 3039 and several provisions of the state and federal Constitutions. The superior court dismissed the petition without reaching the merits of Appellant’s statutory and constitutional arguments. The Supreme Judicial Court vacated the judgment, holding that, given Appellant’s clear challenge to the legality of the DOC rule itself and not its application to his individual circumstances, the court abused its discretion in declining to allow Appellant to amend his complaint and seek relief through a declaratory judgment action. View "Sweeney v. Department of Corrections" on Justia Law

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The Supreme Judicial Court affirmed in part and vacated in part an order of the trial court suppressing evidence seized pursuant to a warrantless search of Defendant’s jacket and vehicle, holding that the search of Defendant’s jacket was a lawful search incident to arrest but that the search of Defendant’s vehicle was not supported by probable cause and was outside the scope of a vehicle search incident to arrest. The trial court concluded that the searches of Defendant’s jacket and vehicles and the seizure of the evidence was not supported by probable cause and violated Defendant’s Fourth Amendment rights. The State appealed, arguing that the search of Defendant’s jacket was a lawful search incident to her arrest and that the evidence discovered in the jacket supported the subsequent search for the illegal drugs discovered in Defendant’s vehicle. The Supreme Judicial Court agreed with respect to the search of Defendant’s jacket but vacated the suppression order as to the evidence found in the vehicle. View "State v. Pagnani" on Justia Law

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The Supreme Judicial Court affirmed Defendant’s conviction for aggravated trafficking of scheduled drugs following his guilty plea, holding that the motion court did not err in denying Defendant’s motion to suppress evidence seized by, and statements made to, police officers after he was arrested without a warrant. On appeal, Defendant argued that the police lacked sufficient probable cause to believe that he was engaged in criminal conduct to justify his warrantless arrest. Therefore, Defendant argued, the statements made and evidence seized after the arrest were subject to suppression. The Supreme Judicial Court disagreed, holding (1) sufficient corroborated information warranted any prudent and cautious person to believe that Defendant was committing the offense of heroin trafficking; and (2) therefore, law enforcement officers properly made the warrantless arrest. View "State v. Journet" on Justia Law

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The Supreme Judicial Court held that an individual resident of Maine was not entitled to a Maine income tax credit for any portion of business taxes imposed by New Hampshire on a New Hampshire limited liability company of which the Maine resident was a member. Appellants, Maine residents, appealed from the judgment of the Business and Consumer Docket affirming the State Tax Assessor’s denial of a tax credit for a share of a New Hampshire business taxes paid by a New Hampshire LLC proportional to the membership interest that Appellants had in the LLC. The court reasoned that no income tax credit applied because (1) the New Hampshire business taxes were imposed on the LLC and were not an “amount of income tax imposed on [an] individual,” Me. Rev. Stat. 36, 5217-A; and (2) Maine’s tax statutes do not violate the Commerce Clause of the federal Constitution. The Supreme Judicial Court affirmed, holding (1) the lower court correctly interpreted Maine’s income tax statutes; and (2) the court did not err in concluding that Maine’s tax statutes are constitutionally sound. View "Goggin v. State Tax Assessor" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated operating under the influence and aggravated assault, holding that the court did not err in denying Defendant’s motion to suppress evidence of his alcohol level determined from a sample of Defendant’s blood that was seized without a warrant. Specifically, the Court held (1) probable cause existed for a law enforcement officer to obtain a sample of Defendant’s blood in the context of an operating under the influence investigation, and (2) exigent circumstances justified the warrantless blood draw because Defendant was about to go into surgery where he would not be available for a blood draw as part of the State’s investigation and his body would further metabolize any alcohol that might be in his blood. View "State v. Palmer" on Justia Law

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The Supreme Judicial Court held that the trial court did not err in determining that the State did not engage in purposeful discrimination when it used a peremptory challenge that excluded from the jury the sole person of color in the jury pool. The Supreme Judicial Court affirmed the judgment of conviction entered in the Unified Criminal Docket convicting Defendant of reckless conduct with a dangerous weapon and criminal threatening with a dangerous weapon. On appeal, Defendant, who described himself as an African American male, argued that the State engaged in purposeful discrimination when it peremptorily challenged the juror at issue. The Supreme Judicial Court disagreed, holding that the trial court did not err when it determined that the prosecutor did not engage in purposeful discrimination. View "State v. Hollis" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court granting Appellant’s petition for postconviction relief and vacating his conviction of sexual abuse of a minor, holding that the court’s factual findings were supported by competent evidence in the record. After a hearing, the postconviction court found that Appellant had been deprived of the effective assistance of counsel and vacated his conviction. The Supreme Court affirmed, holding that the postconviction court’s finding that Appellant had been deprived of the effective assistance of counsel at trial was supported by competent record evidence. View "Fahnley v. State" on Justia Law

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The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress his blood-alcohol test results as having been procured without a warrant and without voluntary consent, holding that Defendant consented to the blood test. The blood test was taken upon probable cause to believe that the ability of Defendant, the driver of the motor vehicle, to operate the vehicle was impaired by intoxicants. On appeal, Defendant argued that the blood test was unconstitutional because it was taken without a warrant and her consent to the test was rendered involuntary by the warning of an increased minimum sentence if she refused to consent and was then convicted. The Supreme Judicial Court disagreed, holding that no coercion results from a law enforcement officer’s statement to a driver that, if she is ultimately convicted of operating under the influence, her failure to submit to a blood draw would subject her to an enhanced criminal penalty, including a minimum mandatory jail term. View "State v. Lemeunier-Fitzgerald" on Justia 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