Justia Maine Supreme Court Opinion Summaries

Appellant was indicted in Cumberland County for burglary and theft by unauthorized taking or transfer. Appellant pleaded nolo contendere to Class C theft by unauthorized taking or transfer. Appellant was subsequently indicted in York County for theft by receiving stolen property. The two indictments concerned the taking of items from a residence in South Portland and the sale of the items in Biddeford. The second case was resolved by a plea agreement. In January 2014, Appellant filed a petition for post-conviction relief from the York County conviction and sentence, claiming that his trial counsel in the York County matter had rendered ineffective assistance by failing to move the York County indictment on double jeopardy grounds. The trial court denied Appellant’s request for relief, concluding that different conduct formed the basis of the Cumberland and York County cases. The Supreme Judicial Court vacated the trial court’s judgment denying Appellant post-conviction relief, holding (1) the second indictment charged Appellant with the same offense for which he had already been convicted and punished; and (2) trial counsel’s failure to seek dismissal of the York County indictment established that Appellant was deprived of his right to effective assistance of counsel. View "Ayotte v. State" on Justia Law

Defendant was charged with criminal operating under the influence. Defendant moved to suppress the evidence of his roadside interactions with a game warden from the moment the game warden parked his marked patrol vehicle behind Defendant’s stopped truck, exited the vehicle, and said, “Hi. Game warden.” The trial court denied the motion to suppress, concluding that the warden did not effect a Terry stop, and therefore, Defendant was not seized within the meaning of the Fourth Amendment prior to the moment the warden observed signs of Defendant’s intoxication. The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress, holding that Defendant was not seized at any time before the warden observed signs of Defendant’s intoxication. View "State v. Ciomei" on Justia Law

After a jury trial, Defendant was convicted of one count of unlawful sexual assault. Defendant later filed a petition for post-conviction review, alleging that his trial counsel failed to provide effective representation during the pretrial and trial proceedings. After a hearing, the superior court denied Defendant’s petition based on its conclusion that Defendant failed to establish that he was “actually prejudiced by any such deficiencies.” The Supreme Judicial Court vacated the post-conviction judgment and remanded for reconsideration, holding that the superior court’s decision applied a test for prejudice that did not fully implement the proper standard of prejudice established in Strickland v. Washington. View "Theriault v. State" on Justia Law

After a nonjury trial, the trial court convicted Defendant of operating while his license was suspended or revoked and sentenced him to thirty days in jail. Defendant appealed, arguing that the trial court did not have jurisdiction to enforce the laws of the “State of Maine” against him and that Maine’s law requiring each driver to hold a valid driver’s license is facially unconstitutional because it violates a purported fundamental right to travel. The Supreme Judicial Court affirmed, holding (1) state jurisdiction over an individual extends to those present within the physical bounds of the state; and (2) the state may, as a valid exercise of its police power, place limitations on the operation of motor vehicles on the state’s roads. View "State v. Pelletier" on Justia Law

After a jury trial, Appellant was found guilty of elevated aggravated assault. The trial court sentenced Appellant to serve twenty-two years in prison. The Supreme Judicial Court affirmed the conviction on direct appeal. Appellant subsequently filed an amended petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance of counsel. The superior court denied Appellant’s petition for post-conviction review, concluding that Appellant received “reasonably effective assistance” of counsel. The Supreme Judicial Court affirmed, holding that Appellant’s attorney provided reasonably effective assistance as required by Strickland v. Washington. View "Manley v. State" on Justia Law

Defendant pleaded guilty in federal court to sexual exploitation of a child and possession of child pornography. Before sentencing, a state grand jury indicted Defendant on thirteen counts of gross sexual assault. Defendant pleaded not guilty to all of the gross sexual assault charges. After the federal district court sentenced Defendant, Defendant filed a motion to dismiss the State’s indictments for gross sexual assault, arguing that the State’s prosecution subjected him to double jeopardy. The trial court denied the motion to dismiss. The Supreme Judicial Court affirmed, holding (1) even if the State’s current prosecution subjects Defendant to the risk of being punished twice for the same conduct, such duplicative punishment is constitutional when, as in this case, the punishments are imposed by separate sovereigns; and (2) there is no evidence to sustain Defendant’s contention that an exception to the “dual sovereignty” doctrine of double jeopardy jurisprudence applied in this case. View "State v. Hoover" on Justia Law

After a hearing, the district court terminated Father’s parental rights pursuant to Me. Rev. Stat. 22, 4055. The Supreme Judicial Court affirmed, holding (1) the district court did not improperly terminate Father’s parental rights solely because he had been diagnosed as having borderline personality disorder and thus did not violate Father’s equal protection rights; (2) the district court provided Father with the due process required in the context of a termination of parental rights by providing him with a reasonable period of time for reunification and not improperly placing a burden of proof upon Father; and (3) there was clear and convincing evidence to support the court’s finding of at least one ground of parental unfitness and that termination was in the child’s best interest. View "In re I.S." on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

Defendant was indicted on one count of unlawfully trafficking in scheduled drugs and one count of illegal importation of scheduled drugs. Defendant filed a motion to suppress as evidence illegal drugs seized from him by law enforcement officers after they stopped a vehicle in which he was a passenger. The trial court granted the motion to suppress, concluding that the warrantless search of the clothes Defendant was wearing exceeded the bounds of a valid protective search or justifiable search for contraband. The Supreme Court vacated the suppression order, holding that the search was justified by probable cause and the existence of exigent circumstances, and therefore, the search was constitutional. Remanded. View "State v. Martin" on Justia Law