Justia Maine Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Maine v. Bragg
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
Maine v. Patton
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
O’Brien v. Weber
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
Maine v. Prescott
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
Maine v. Haag
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
Maine v. Koehler
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
Maine v. Poole
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
D’Alessandro v. Town of Harpswell
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
Maine v. Jones
Defendant Kevin Jones appealed a district court's judgment following a bench trial at which he was found guilty of carrying a concealed weapon. On appeal, Defendant argued that the evidence was insufficient to establish beyond a reasonable doubt that knives he carried were statutorily prohibited from being concealed. Because the statute's prohibitions applicable to knives are limited to those knives that, in their design or primary function, constitute a "dangerous or deadly weapon usually employed in the attack on or defense of a person," the Supreme Court vacated the conviction. View "Maine v. Jones" on Justia Law
Maine v. Lemay
Defendant Bradley Lemay appealed his convictions of felony gross sexual assault; criminal threatening with a dangerous weapon' eluding an officer; attempted escape; and tampering with a victim. The charges stemmed from three events that occurred on three different dates. Defendant argued that the court abused its discretion by joining the matters for trial pursuant to M.R. Crim. P. 8(a), and by subsequently denying his motion for relief from prejudicial joinder pursuant to M.R. Crim. P. 8(d). Upon review, the Supreme Court affirmed: "The record makes clear that the court carefully considered and thoroughly evaluated Lemay’s arguments. The court also took care to give relevant instructions to the jury to reduce the potential for prejudice resulting from the joinder. Lemay failed to prove that any inadmissible evidence would be or was admitted due to the joinder, or that his choice not to testify interfered with his ability to present his defense. Given that the trial court has wide discretion to join and sever trials, on this record it was not an abuse of discretion for the court to ultimately conclude that the balance in this case tipped in favor of joinder."
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