Justia Maine Supreme Court Opinion Summaries

NDC Communications, LLC and Kenneth Carle III engaged in a complex set of agreements in the context of the development of a piece of land. When the parties’ working relationship broke down, NDC filed a complaint asserting that it was owed funds from Carle, and Carle counterclaimed seeking contract remedies and other relief. The trial court ultimately entered judgment enforcing a mechanic’s lien against Carle in the amount of $336,681.24. Carle appealed, arguing, inter alia, that the trial court failed to provide him a credit due of approximately $25,000, rendering the judgment against him inaccurate. The Supreme Judicial Court affirmed, holding (1) Carle’s due process rights were not violated by the post-trial procedures employed by the court; and (2) there was sufficient evidence in the record to support the court’s judgment, including its determination of damages. View "NDC Communications, LLC v. Carle" on Justia Law

After a jury trial, Defendant was convicted of two counts of gross sexual assault, four counts of impersonating a public servant, and two counts of engaging a prostitute. The convictions were based on Defendant’s pretending to be a police officer in order to induce three of four women who were engaged in prostitution to have sex with him as he demanded. Defendant appealed, arguing that the indictment and jury verdict form did not adequately distinguish among separate allegations involving each victim, in violation of his due process rights. The Supreme Judicial Court affirmed, holding that the constitutional issues that Defendant now asserts were waived. View "State v. Foster" on Justia Law

Defendant entered a conditional guilty plea to the Class B charge of unlawful trafficking in scheduled drugs. Defendant appealed, challenging the denial of his motion to suppress statements he made during an interrogation. Specifically, Defendant argued that his statements made during the custodial interrogation must be suppressed because law enforcement did not specifically advise him that he had the right to the presence of counsel during questioning. The Supreme Judicial Court affirmed, holding that, under the circumstances of this case, Defendant was adequately advised of his constitutional right to counsel and that he effectively waived the privilege against self-incrimination, rendering his statements admissible against him at trial. View "State v. Figueroa" on Justia Law

Defendants, two cousins, were convicted of unlawful trafficking in scheduled drugs. Defendants appealed, challenging the trial court’s denial of their motion to suppress evidence obtained during a warrantless search and during police questioning. The Supreme Court affirmed, holding (1) the court did not err in concluding that the warrantless search was valid because neither of the defendants affirmatively denied the officer consent to conduct the search; and (2) the court did not err in concluding that one of the defendant’s statements made while he was in custody but before he was informed of his Miranda rights was admissible under the public safety exception to Miranda. View "State v. Carton" on Justia Law

In 2015, the Department of Health and Human Services filed a petition to terminate Father’s parental rights to his son. At the commencement of the termination hearing, Father told the court that he was unwell and that he wanted to reschedule the hearing. The court allowed Father to leave and told him the hearing would be rescheduled if Father filed a doctor’s note. Father never filed a doctor’s note and no rehearing was scheduled. The court subsequently terminated Father’s parental rights. The Supreme Judicial Court affirmed, holding that the court did not violate Father’s right to due process when it conducted the termination hearing in Father’s absence. View "In re Adden B." on Justia Law

After a jury trial, Defendant was convicted of murder and arson. Defendant was sentenced to life imprisonment for the murder. During the proceedings, the trial court excluded GPS data and handwritten notes from the State’s case-in-chief due to hearsay problems or discovery violations. The court, however, stated that it would revisit its ruling regarding the admissibility of the evidence should it be necessary for impeachment purposes. On appeal, Defendant argued that the trial court’s evidentiary rulings violated his right to a fair trial by preventing him from presenting evidence contrary to the facts indicated in the excluded evidence. The Supreme Judicial Court affirmed, holding that the court’s rulings excluding the evidence at issue from use in the State’s case-in-chief were not an abuse of discretion and did not violate Defendant’s constitutionally guaranteed right to a fair trial. View "State v. Poulin" on Justia Law

The two defendants in this case - James Simmons and Frederick Campbell - were each charged with and indicted for two counts of arson. Simmons filed a motion to suppress the evidence seized as a result of search warrants, arguing that the search warrants were not supported by probable cause. The superior court granted the motion and suppressed evidence of cellular telephone records seized pursuant to the warrants. The Supreme Judicial Court vacated in part and affirmed in part, holding (1) the affidavits established probable cause for the State to seize those portions of Simmons’s cell phone records relating to historical cell site location data for a certain day; and (2) the remaining aspects of the suppression order as to Simmons and the order in its entirety as to Campbell were without error. View "State v. Simmons" on Justia Law

Defendant entered a conditional plea of nolo contendere to the crime of operating after suspension. A judgment of conviction was entered accordingly. Defendant appealed, arguing that the lower court erred in denying his motion to suppress because the law enforcement officer’s decision to stop his vehicle was pretextual and the stop was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding that the record supported the court’s inferred finding that the stop was supported by a reasonable articulable suspicion of a threat to public safety, and therefore, the lower court did not err in denying Defendant’s motion to suppress. View "State v. Sasso" on Justia Law

At jury selection for Frisbee’s trial on charges of unlawful sexual contact, Frisbee’s attorney saw a former client, who had no connection to the matter, in the courtroom. The spectator had spent 11 months in prison for threats against Frisbee’s attorney and his family. In addition, both the judge and the State’s Attorney had previously prosecuted the spectator, who had just been released from prison for criminal threatening involving potential juror 116, later empaneled on the case. The spectator was glaring, making gestures, and smirking. The court instructed the marshals to remove the spectator. Jury selection continued without incident. During trial the spectator reappeared, closer to juror 116. The court ordered a recess and discussed the matter with the State and Frisbee’s attorney, who reported that the spectator had been seen with a weapon. The court directed security to take the spectator through security screening and interviewed juror 116, who stated that she was “very distracted.” The court excluded the spectator from the trial. The next day, the court learned that the spectator had been in the building and had approached jurors, asking them to take a copy of a book that he had written. Frisbee’s attorney requested that the jury be sequestered. The court questioned each juror; all except juror 116 stated that they had not been distracted and all of stated that the spectator in no way would affect their ability to be fair and impartial. The court denied the request. Later, the court and the parties learned that the spectator had left his notebook at the courthouse, with a threatening statement. Frisbee unsuccessfully moved for a mistrial. The Maine Supreme Judicial Court affirmed Frisbee’s conviction and sentence, finding that he had received a fair trial. View "State of Maine v. Frisbee" on Justia Law

Defendant entered a conditional plea to the charge of operating under the influence with two prior convictions for operating under the influence. Defendant appealed the denial of his motion to suppress the evidence obtained from a stop of his vehicle. The trial court concluded that, by a preponderance of the evidence, the arresting officer had an objectively reasonable belief that Defendant had violated Me. Rev. Stat. 29-A, which prohibits braking or accelerating that is “unnecessarily made so as to cause a harsh and objectionable noise.” The Supreme Judicial Court affirmed, holding that there was no error in the court’s findings of fact or conclusions of law. View "State v. Violette" on Justia Law