Justia Maine Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of gross sexual assault and two counts of unlawful sexual contact, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the district court did not abuse its discretion in denying Defendant's motion for a continuance; (2) there was no constitutional error in the trial court's ruling requiring that participants in Defendant's trial be masked; (3) there was no prosecutorial error in either the State's opening or closing argument or in the State's rebuttal argument; and (4) Defendant's claims of evidentiary error were unavailing. View "State v. Hunt" on Justia Law

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The Supreme Judicial Court vacated the judgment of the post-conviction review (PCR) court denying Appellant's PCR petitions, holding that the PCR court misconstrued aspects of the relevant law.In his speedy trial petitions, Defendant argued that his rights to a speedy trial had been violated and that his trial counsel provided ineffective assistance by failing to raise his speedy trial claims. The PCR court denied the petition. Thereafter, Defendant sought a certificate of probable cause. The Supreme Judicial Court vacated the judgment below, holding (1) the PCR court utilized a faulty analysis in concluding that there was no merit to Defendant's speedy trial claim; and (2) because the PCR court did not analyze counsel's strategy in failing to assert Defendant's right to a speedy trial the case must be remanded. View "Winchester v. State" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of one count of aggravated trafficking in scheduled drugs and two counts of criminal forfeiture, holding that the trial court did not err in denying either Defendant's motion to suppress or his motion for discovery.On appeal, Defendant argued that the trial court erred when it denied his motion to suppress and his request for additional discovery relating to the State's cooperating defendant. The Supreme Judicial Court affirmed, holding (1) law enforcement agents had probable cause to support their stop of Defendant, and therefore, the trial court did not err when it denied Defendant's motion to suppress; and (2) the trial court did not abuse its discretion in denying Defendant's discovery motion. View "State v. Lepenn" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder but vacated his sentence, holding that a criminal defendant's decision to exercise his constitutional right to a trial by jury may not be considered at sentencing.After a seven-day trial at which Defendant did not testify, the jury returned a verdict of guilty to murder. After a sentencing hearing, the court found that there were no mitigating circumstances and imposed a thirty-two-year sentence. The Supreme Judicial Court vacated Defendant's sentence, holding that the trial court (1) did not err when it denied Defendant's request to provide him with access to the grand jury transcript; but (2) abused its discretion by referencing Defendant's demand for a jury trial in determining the genuineness of Defendant's claim of personal reform and contrition. View "State v. Moore" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered upon Defendant's conditional guilty plea after the trial court denied his motion to suppress evidence obtained through a police officer's interactions with him in a convenience store parking lot, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant moved on multiple grounds to suppress evidence obtained as a result of his interactions with the police officer, arguing that he was unlawfully seized based on an unreliable anonymous tip and was directed to perform field sobriety testing without given a chance to decline. The court denied the motion to suppress. Defendant then entered a conditional guilty plea to operating under the influence. The Supreme Judicial Court affirmed, holding that the officer did not violate the United States Constitution by conducting field sobriety tests under the circumstances of this case. View "State v. Wilcox" on Justia Law

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The Supreme Judicial Court affirmed the final judgment and order of the district court in Husband's divorce from Wife and imposed sanctions, holding that Husband's appeal was frivolous and contumacious within the meaning of M. R. App. P. 13(f).On appeal, Husband contended that the trial court both violated his rights to due process by failing to hold a trial and made impermissible changes to the parties' mediation agreement. The Supreme Judicial Court affirmed, holding (1) there was no violation of Defendant's due process rights; (2) the final divorce judgment accurately incorporated the terms of the parties' agreement; and (3) Husband should be sanctioned for this frivolous and contumacious appeal. View "Aubuchon v. Blaisdell" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction and sentence for gross sexual assault but remanded for the court to determine the appropriate length and conditions of supervised release to be imposed, holding that there was otherwise no error.Specifically, the Supreme Judicial Court held (1) because a principal and accomplice are not subject to different processes or analyses when a sentencing court applies the Hewey analysis set out in Me. Rev. Stat. 17-A, 1602, the sentencing court did not err when it set the basic sentence at twenty years in compliance with Me. Rev. Stat. 17A-1252(4-E); and (2) remand was required for the district court to determine the length and conditions of supervised release to be imposed and to articulate its analysis and the factors that led to its decision. View "State v. Ringuette" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of, among other charges, seventeen counts of sexual exploitation of a minor under the age of twelve, holding that a search of Defendant's smartphone did not violate Defendant's rights under the Fourth Amendment.On appeal, Defendant argued that the trial court abused its discretion when it declined to reach its argument that the warrant supporting the search of his cellphone was overbroad and violated the particularity requirement of the Fourth Amendment. The Supreme Judicial Court disagreed and affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress; and (2) Defendant's remaining arguments on appeal were without merit. View "Maine v. Jandreaud" on Justia Law

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The Supreme Judicial Court vacated the judgment of conviction of attempted murder and other offenses entered by the trial court, holding that multiple acts of prosecutorial error occurred in this case, requiring remand for a new trial.A jury found Defendant guilty of attempted murder, elevated aggravated assault, robbery, and reckless conduct with a dangerous weapon. On appeal, Defendant principally argued that the trial court erred in denying his repeated motions for a mistrial based on allegedly improper comments made during the prosecution's opening statement, closing statement, and rebuttal. The Supreme Judicial Court agreed and remanded the case for a new trial, holding (1) the State committed error in its opening statement and closing argument; and (2) because Defendant's substantial rights were impaired, under Me. Const. art. I, 6 and 6-A and this Court's supervisory power, the appropriate remedy in this case was a new trial. View "State v. White" on Justia Law

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The Supreme Court vacated the judgment of the trial court convicting Defendant on two charges of aggravated furnishing of cocaine, which were merged for sentencing, holding that the trial court erred when it denied Defendant's motion to suppress, and the error was not harmless.At issue was the denial of Defendant's motion to suppress evidence obtained when police officers stopped him after receiving an anonymous tip and searched his belongings outside a bus station. The trial court concluded that the officers had an objectively reasonable, articulable suspicion that Defendant had been engaged in criminal activity when they stopped they stopped him. The Supreme Court vacated the judgment below, holding that the evidence regarding the anonymous tip and the police's efforts to confirm its reliable failed to establish an objectively reasonable, articulable suspicion sufficient to justify the stop. View "State v. Barclift" on Justia Law