Justia Maine Supreme Court Opinion Summaries

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

John and Jane Doe, the parents Susan Doe, a transgender girl, filed a complaint with the Maine Human Rights Commission alleging that Regional School Unit 26 (RSU 26) had violated the Maine Human Rights Act (MHRA) by excluding Susan from the communal girls’ bathroom at elementary and middle school. The Commission found reasonable grounds to believe discrimination had occurred. Thereafter, the Does and the Commission filed a complaint in the superior court asserting claims for unlawful discrimination in education (Count I) and unlawful discrimination in a place of public accommodation (Count II) on the basis of sexual orientation. The superior court granted RSU 26’s motion for summary judgment on all counts. The Supreme Court vacated the judgment of the superior court, holding that where it has been clearly established that a student’s psychological well-being and educational success depend on being permitted to use the communal bathroom consistent with her gender identity, denying the student access to the appropriate bathroom constitutes sexual orientation discrimination in violation of the MHRA. Remanded for entry of summary judgment for the Does and the Commission. View "Doe v. Reg'l Sch. Unit 26" on Justia Law