Justia Maine Supreme Court Opinion Summaries

Since 1983, Michael Dee repeatedly and unsuccessfully challenged in state and federal courts the constitutionality of Maine marijuana prohibitions. In 2007, the superior court enjoined Dee from filing further lawsuits in Maine courts challenging the constitutionality of the State’s marijuana laws. Despite this injunction, Dee did not request the court’s permission to file this complaint for a judgment declaring that provisions in several Maine marijuana statutes were unconstitutional until almost one month after his complaint was docketed. The superior court dismissed Dee’s complaint with prejudice, finding that several Maine courts had already considered and rejected Dee’s arguments and that the suit was frivolous. The Supreme Court affirmed, holding that in light of the frivolous and duplicative nature of the suit and Dee’s failure to seek permission before commencing this action, the superior court did not abuse its discretion in granting the State’s motion to dismiss Dee’s petition with prejudice. View "Dee v. State" on Justia Law

After a jury trial, Defendant was found guilty of several sex offenses. The Supreme Court affirmed after clarifying the conduct the State was required to prove in order to prove the element of penetration, holding that the trial court did not err in (1) denying Defendant’s motion for a judgment of acquittal on the charge of unlawful sexual conduct, as the jury could have rationally made the finding that the State proved beyond a reasonable doubt every element of the offense; and (2) conducting voir dire, as no individual voir dire member disclosed a general bias against a defendant with mental illness.View "State v. Gladu" on Justia Law

When Mother and Father divorced, primary custody of M.M. was awarded to Mother. Later, the district court modified the judgment by awarding sole parental rights to Father. Petitioners - Mother’s investigator and three private citizens with no natural or legal relationship to M.M. - subsequently filed a petition for a child protection order seeking to have the district court find that M.M. required protection because of circumstances of jeopardy created by Father. The court dismissed the petition, finding that some of the claims asserted were barred by the doctrine of res judicata, other claims failed to state a claim upon which relief could be granted, and Petitioners lacked standing. The Supreme Court concluded that Petitioner had standing to bring the petition for a child protection order and otherwise affirmed the judgment.View "In re M.M." on Justia Law

After a jury trial, Defendant was convicted of criminal operating under the influence and refusing to sign a uniform summons and complaint. On appeal, Defendant argued, among other things, that he did not properly waive his right to be assisted by counsel at trial. The Supreme Court vacated the judgment, holding that the record did not reflect - either through Defendant’s own responses to the court regarding the trial process, counsel’s statements regarding Defendant’s waiver, or evidence regarding whether Defendant was informed about the trial process - that Defendant voluntarily, knowingly, and intelligently waived his constitutional right to counsel.View "State v. Hill" on Justia Law

After a jury trial, Defendant was found guilty of operating after habitual offender revocation. Defendant appealed, arguing (1) the trial court erred when it failed to clarify the definition of “public way” as defined in Me. Rev. Stat. 17-A, 505(2); (2) the statute’s language is confusing and unconstitutionally vague; and (3) the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) Defendant failed to preserve her clarification argument; (2) the language of the statute is outdated and confusing but describes a certain type of public way with sufficient certainty to survive a due process challenge; and (3) the evidence was sufficient to support the verdict.View "State v. Stanley" on Justia Law

After a jury trial, Defendant was found guilty of manslaughter. Defendant appealed, arguing that the trial court erred in denying his motion to suppress because he was subjected to custodial interrogation and did not receive Miranda warnings and because he was in a state of shock and emotional distress that rendered his statements involuntary. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Defendant’s statements were not made in the course of custodial interrogation for purposes of Miranda; and (2) the trial court did not err in determining that Defendant’s statements were made voluntarily. View "State v. Bryant" on Justia Law

Defendant’s probation officer asked Defendant to come to the probation office. When Defendant complied, he met two state troopers who sat down with him and asked him about a theft at the victim’s apartment. After the interview, Defendant made incriminating statements. Defendant was charged with burglary and theft by unauthorized taking or transfer. Defendant moved to suppress the statements he made to law enforcement. The trial court determined that Defendant spoke voluntarily and that he was not in custody, and therefore, Miranda warnings were not required. Defendant was subsequently convicted of theft by unauthorized taking or transfer. The Supreme Court affirmed, holding (1) the trial court did not err in determining that Miranda warnings were unnecessary because Defendant was not in custody; (2) the trial court did not err in concluding that the confession was voluntary; and (3) the evidence was sufficient to support the conviction. View "State v. Kittredge" on Justia Law

After a jury-waived trial, Defendant was convicted of failing to provide his correct, name, address, and date of birth; possession or distribution of dangerous knives; and refusing to submit to arrest or detention. The Supreme Court vacated Defendant’s conviction of failing to give his correct name, address, and date of birth but otherwise affirmed, holding (1) the trial court did not violate Defendant’s Confrontation Clause rights at a suppression hearing by admitting testimony of police officers because the testimony was not hearsay; and (2) the evidence presented at trial was insufficient to sustain Defendant’s conviction of failing to give his correct name, address, and date of birth. View "State v. Johnson" on Justia Law

In 2013, Defendant was tried on a charge of domestic violence assault. During the trial proceedings, the trial court granted Defendant’s motion for a mistrial after finding manifest necessity to declare a mistrial. Concluding that the mistrial did not involve prosecutorial misconduct, the trial court ruled that the State was entitled to retry its case. Defendant appealed, arguing that double jeopardy barred retrial. The Supreme Court affirmed, holding that because Defendant consented to a mistrial, and because intentional prosecutorial misconduct did not bar a retrial, there was no barrier to retrial under the double jeopardy clause. View "State v. Johnson" on Justia Law

After a jury trial, Appellant was convicted of assault on an officer and criminal mischief. Appellant appealed, arguing that his trial counsel provided ineffective assistance by electing not to make an opening statement, not cross-examining the State’s witnesses, not presenting any evidence for the defense, and presenting only a brief closing argument. The Supreme Court affirmed, holding that the issues Appellant raised regarding ineffective assistance of counsel were not properly raised on direct appeal and instead must be addressed in a fact-finding proceeding to determine if trial counsel’s action resulted from incompetence, appropriate strategic choices, or other considerations. View "State v. Troy" on Justia Law