Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of murder and sentenced to forty-five years in prison. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to law enforcement officers in the hours following the murder because he was in a state of intoxication and emotional distress at the time that rendered his statements involuntary. The Supreme Court affirmed, holding that the court did not err in determining that Defendant’s statements to law enforcement were the free choice of a rational mind, were fundamentally fair, and were not a product of coercive police conduct. View "State v. Kierstead" on Justia Law

In two criminal cases, Defendant was indicted on several charges, including unlawful trafficking in synthetic hallucinogenic drugs and conspiracy to commit unlawful trafficking in synthetic hallucinogenic drugs. Defendant filed a motion to dismiss the two cases, arguing that the statute defining a “synthetic hallucinogenic drug” is unconstitutionally vague. The superior court denied the motions to dismiss. Defendant subsequently entered conditional guilty pleas. The Supreme Court affirmed, holding (1) the term “derivative” used in the statute is not unconstitutionally vague; and (2) the statute as a whole is not unconstitutionally vague. View "State v. Reckards" on Justia Law

After a jury trial, Defendant was convicted of aggravated trafficking of scheduled drugs and refusal to submit to arrest or detention. The Supreme Judicial Court affirmed the judgment, holding (1) the trial court did not err or violate Defendant’s constitutional rights by sustaining the State’s objection to Defendant’s cross-examination of a certain witness about the nature of the locale where the crime allegedly occurred based on weaknesses in the probative value of the evidence; and (2) the trial court did not err when it denied Defendant’s motion for a judgment of acquittal, as the evidence was sufficient to support the jury’s guilty verdict. View "State v. Adams" on Justia Law

Between 2002 and 2008, Defendants applied for, were found qualified for, and lived in Section 8 housing, for which the local housing authority paid a substantial rent subsidy to the landlord. Throughout this time, Defendants earned income far in excess of the maximum that would qualify them for Section 8 housing assistance. Defendants were eventually convicted of theft by deception. Defendants appealed, arguing that the trial court erred in admitting into evidence as business records certain forms on which Defendants had provided financial information. The Supreme Court affirmed the judgments, holding that the trial court did not abuse its discretion in admitting the forms into evidence. View "State v. Abdi" on Justia Law

Defendant was charged with unlawful trafficking of scheduled drugs and seeking criminal forfeiture of cash discovered during the search of his vehicle by Maine Drug Enforcement Agency (MDEA) agents. Defendant filed a motion to suppress the evidence gathered from the search. The suppression court denied the motion, concluding that MDEA had sufficient probable cause to search the vehicle based on the totality of the circumstances. The Supreme Court affirmed, holding that because Defendant failed to show his reasonable expectation of privacy in the vehicle, his Fourth Amendment rights were not violated by the search. View "State v. Lovett" on Justia Law

In 2003, John Doe XLVI pleaded guilty to and was convicted of possession of sexually explicit material. When Doe was sentenced, possession of sexually explicit material was not a sex offense requiring registration under Maine’s Sex Offender Registration and Notification Act of 1999 (SORNA), and therefore, Doe was not ordered to comply with SORNA. Possession of sexually explicit material was subsequently added to the list of sex offenses. In 2009, the Legislature amended SORNA to provide that a duty to register “is not triggered by a court determination, but by and upon notification.” In 2012, Doe received a notice of the duty to register. Doe filed this action seeking to enjoin the State from pursuing criminal charges against him for failing to register, alleging, inter alia, that SORNA was an invalid bill of attainder. The superior court rejected Doe’s challenges. The Supreme Court vacated the judgment of the trial court, holding that SORNA is punitive as to offenders who were not sentenced to comply with SORNA when SORNA registration was part of sentencing and who were subsequently subjected to SORNA registration when their earlier offenses were added to the statutory list of sex offenses and registration was removed from sentencing. View "John Doe XLVI v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of perjury. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by allowing the State to introduce testimony regarding Defendant’s silence following his arrest for operating under the influence (OUI) and by allowing the State to refer to this testimony during closing argument; (2) Defendant failed to establish that the trial court abused its discretion in allowing a police officer to testify to his opinion that “there were lies told” during Defendant’s trial for OUI, at which Defendant was acquitted, or that the opinion was prejudicial to him; and (3) admitting the testimony of a Verizon employee about the contents of Defendant’s cell phone billing record that the State offered as the testimony of a custodian of records. View "State v. Wyman" on Justia Law

In 2013, pursuant to the Freedom of Access Act (FOAA), Phillip Bowler requested a copy of the Attorney General’s investigative file concerning a death that occurred in 1953. The Deputy Attorney General denied Bowler access to the file on the ground that it was designated confidential by statute. Bowler appealed to the superior court. The superior court denied the appeal. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the file was made confidential by statute; (2) the Attorney General did not waive the statutory confidentiality of the file by releasing a copy to the decedent’s family; and (3) Defendant’s argument that releasing the file to a family member but not to him violated his constitutional right to equal protection failed. View "Bowler v. State" on Justia Law

After a jury trial, Defendant was convicted for operating after revocation. The Supreme Court affirmed the judgment as amended, holding (1) any error by the trial court in refusing to instruct the jury about certain statutory requirements applicable to written notices of revocation was harmless; and (2) even if the State improperly offered and used documents that Defendant alleged were not properly identified as part of an exhibit but nonetheless were presented to the jury did not rise to the level of obvious and reversible error. Remanded for correction of an improper statutory reference in the judgment and commitment order. View "State v. Garcia" on Justia Law

Defendant was at the place of his employment when his employer asked him to submit to a breath test. The results from the employer’s self-contained portable breath-alcohol testing device showed that Defendant had indicators of alcohol in his system, and Defendant was sent home on unpaid leave. Defendant was driving his van after leaving his place of employment when he was stopped and arrested. A police officer administered several field sobriety tests after stopping Defendant. Defendant was subsequently charged with driving under the influence. Before trial, the court granted the State’s motion in limine to exclude any evidence of the workplace breath-alcohol test to challenge the accuracy of the State’s intoxilyzer test. Defendant entered a conditional guilty plea to the charge then appealed the order on the motion in limine. The Supreme Court vacated the judgment, holding that Defendant was entitled to challenge the reliability of the test results offered by the State by any appropriate means that is otherwise admissible in evidence, and thus the trial court denied Defendant the opportunity to make a formal offer of proof by excluding evidence of the workplace breath-alcohol test. View "State v. Adams" on Justia Law