Justia Maine Supreme Court Opinion Summaries

Paul Clark obtained a temporary protection from abuse order on behalf of his thirteen-year-old son against Defendant Michelle Fundalewicz, the child’s mother and Paul’s ex-girlfriend. At the time, the child resided with Paul and Paul’s then-fiancée (now wife), Miranda Clark. The child received a phone call on the home’s landline while Paul or both Paul and Miranda were not home. The child eventually revealed that Defendant had called him earlier that day. Paul reported the incident to the police. The child provided a written statement to the police stating that Defendant did call and speak with him. The State charged Defendant with violation of a protection order; Defendant pled not guilty to the charge and the matter proceeded to a jury-waived trial. At trial, the child testified that it was instead his cousin who called him. He testified that he said it was Defendant in his written statement to police because Paul had told him that if he did not name Defendant, the child would have to move back in with his mother where he would "get treated like crap" as he had been when he lived with her in the past. Miranda testified that a few days after the incident, she spoke with Defendant on the phone, and Defendant admitted to having called and spoken with the child. At the close of the trial, Defendant orally moved for a judgment of acquittal on the grounds that "the State failed to establish a corpus for the offense charged" because the State did not provide "evidence independent of any potentially incriminating statements that [Fundalewicz] . . . made." The court denied the motion, found Defendant guilty of violating the protection order, and sentenced her to pay a $400 fine. Although largely circumstantial, the Supreme Court concluded that the evidence presented at trial, along with the reasonable inferences that could have been drawn from it, adequately supported the corpus delicti requirement, as well as the court’s finding that Defendant did in fact call her son in violation of the protection order. View "Maine v. Fundalewicz" on Justia Law

Daniel Whitney appealed his conviction on one count of operating under the influence following his conditional guilty plea. Whitney argued on appeal that the trial court erred in issuing an order denying his motion to suppress evidence derived from a police officer's stop of his vehicle. Because the Supreme Court concluded that the stop was unconstitutional, it vacated the judgment and the order denying the motion to suppress. View "Maine v. Whitney" on Justia Law

Defendant Tammy Bragg appealed her conviction for operating under the influence following a jury trial. On appeal, Defendant contended that the court erred when it refused to suppress statements she made at the scene of the accident and at the police station. After review of the trial court record, the Supreme Court affirmed the judgment. View "Maine v. Bragg" on Justia Law

Defendant Aaron J. Patton appealed his conviction following a jury trial at which he was found guilty of four counts of gross sexual assault; one count of unlawful sexual contact; and two counts of sexual abuse of a minor. Upon review, Defendant contended that the court erred in several respects, including: (1) a constitutional error resulting from the court's decision to permit a State's witness (a police officer) to testify over his objection about Defendant's assertion of his right to remain silent shortly before his arrest; (2) the admission of evidence of Defendant's use of hypnosis; (3) the admission of police officer testimony that contained inadmissible hearsay evidence and was unfairly prejudicial; and (4) the misstatement of jury instructions. Upon review of the superior court record, the Supreme Court disagreed and affirmed the judgment. View "Maine v. Patton" on Justia Law

William Weber, Jr. appealed a protection from abuse order entered in district court on a complaint filed by Maureen O'Brien on behalf of her sixteen year old daughter. Weber contended that the court lacked authority to enter a new protection order based solely on the same act of abuse that was the subject of an expired, unextended protection order between the same parties. Upon review, the Supreme Court agreed and vacated the judgment. View "O'Brien v. Weber" on Justia Law

Defendant Rachel Prescott appealed her conviction following a conditional guilty plea to operating while under the influence and for failing to report an accident. Defendant's plea preserved her right to appeal the trial court's order that denied her motion to suppress evidence derived from police questioning. Defendant argued on appeal that she was not technically in police custody at the time she was questioned because she was not read her rights nor did the police use its crusier lights when transporting her from the scene of the accident. Upon review, the Supreme Court concluded Defendant was in custody at the time of her questioning, and vacated the judgment and part of the suppression order entered in Defendant's case. View "Maine v. Prescott" on Justia Law

Defendant Colin Haag appealed his conviction on two counts of kidnapping after a jury trial at superior court. Defendant was charged with kidnapping stemming from divorce proceedings through which Defendant's ex-wife withheld access to Defendant's two daughters. On appeal, Defendant contended that the evidence presented at trial was insufficient to support his convictions and that the court erred in denying his motion for judgment of acquittal. Upon review of the superior court record, the Supreme Court found the evidence sufficient to support Defendant's conviction, and affirmed the superior court's judgment. View "Maine v. Haag" on Justia Law

After a jury trial, Defendant Colin Koehler was found guilty of the intentional or knowing murder of a young woman he had known for less than a day, for which the court sentenced him to life in prison. On appeal, Defendant challenged several rulings on evidence, procedure, motions, and jury instructions. He also challenged his sentence primarily on the grounds that there was insufficient evidence of premeditation, that he has no substantial criminal history, and that his mental health evaluations failed to reveal any significant psychological or psychiatric disorders linked to criminality. Upon review, the Supreme Court found no error in the trial court’s rulings and concluded that the court acted within its sentencing authority in imposing a life sentence. View "Maine v. Koehler" on Justia Law

Defendant Jacklyne S. Poole appealed her conviction on domestic violence assault following a bench trial. Defendant's charge arose from an incident in which she assaulted her boyfriend. She was sentenced to 180 days in jail, all suspended, and one year of probation. On appeal, Defendant argued: (1) that the court erred by denying her motion to enlarge time to file a jury trial request after the twenty-one-day deadline imposed by M.R. Crim. P. 22 because she did not knowingly and intelligently waive her right to a jury trial at arraignment; and (2) the application of different procedural rules for accessing the jury trial right in courts with and without Unified Criminal Dockets violated the federal and Maine constitutional guarantees of equal protection. Upon review, the Supreme Court found no error in the trial court's decisions, and affirmed the judgment. View "Maine v. Poole" on Justia Law

Petitioners David F. and Jeannette A. D'Alessandro appealed a superior Court judgment that affirmed a Town of Harpswell Board of Appeals decision. The Board had denied the D'Alessandros' appeal of a permit issued by the code enforcement officer to several subdivision landowners to install a seasonal stairway for shore access over an easement that burdens land the D'Alessandros own in the same subdivision. The D'Alessandros opposed the permit, arguing that the Harpswell Shoreland Zoning Ordinance allowed for only one stairway to the shore in this subdivision and there was an existing stairway providing shore access in another location within the subdivision. Upon review, the Supreme Court vacated and remanded for further proceedings: The Board's finding that "the location of the proposed stairs is reasonable under the ordinance" did not apply the standard as it is set forth in the ordinance and provided no finding regarding the actual question presented by the ordinance: did a reasonable access alternative exist? Thus, although the Supreme Court reviewed the Board's factual findings under a deferential standard of review, here the Board erred because it failed to make a finding as to whether there was no reasonable access alternative. View "D'Alessandro v. Town of Harpswell" on Justia Law