Justia Maine Supreme Court Opinion Summaries

While on patrol, a state police trooper clocked a Pontiac traveling at a speed well above the speed limit. As the trooper was making a turn to pursue the car, a motorcycle driven by Ronald LaPlante passed him. The trooper lost sight of the car but did come upon the motorcycle. The trooper stopped LaPlante for the sole purpose of asking about the direction of the Pontiac but obtained sufficient for the State to charge LaPlante with criminal operating under the influence. LaPlante moved to suppress the evidence obtained during the vehicle stop, but the superior court denied the motion. LaPlante was then convicted of operating under the influence. On appeal, the Supreme Court vacated the judgment, holding (1) a law enforcement officer's investigation of a third party's civil speeding offense does not justify the discretionary seizure of a motorist in the absence of reasonable articulable suspicion, and (2) the superior court erred when it denied LaPlante's motion to suppress. Remanded. View "State v. LaPlante" on Justia Law

After pleading guilty to criminal charges, Terry Chesnel received judgments of conviction requiring him to pay $3700 in court fines. Soon after Chesnel was incarcerated, the Department of Corrections began withdrawing twenty-five percent of all funds deposited into Chesnel's prison account to satisfy his court fines. Chesnel later filed a petition for post-conviction review, asserting that he had been denied effective assistance of counsel. His petition did not mention the Department's collection of funds from his prison account. The superior court denied Chesnel's petition, and no appeal was taken. Two years later, Chesnel filed a motion to modify the conditions governing the collection of his court fines while he was in prison. The superior court denied the motion. Chesnel appealed, contending, inter alia, that the Department's collection of funds without notice or hearing was an unconstitutional taking and violation of due process. The Supreme Court dismissed the appeal, holding that because Chesnel did not raise the issue through a petition for post-conviction review, the superior court did not have jurisdiction to entertain Chesnel's motion. Remanded to the superior court for a dismissal of the motion. View "State v. Chesnel" on Justia Law

Kaihlil Nigro was convicted of two counts of aggravated trafficking of scheduled drugs with an accompanying order for criminal forfeiture following a jury trial. Nigro appealed, contending that he was deprived of a fair trial because the court did not ask prospective jurors whether they harbored prejudice or bias against members of the Islamic faith. Nigro also argued that the court erred in refusing to suppress (1) an out-of-court photographic identification made by a confidential informant, (2) evidence obtained during the execution of a search warrant, and (3) documents seized during his arrest. The Supreme Court affirmed, holding (1) Nigro did not establish that the court committed obvious error in conducting voir dire, (2) the informant's identifications were properly admitted at trial despite an unnecessarily suggestive identification procedure, (3) the search warrant affidavit sufficiently established probable cause, and thus the evidence obtained during the execution of the search warrant was properly admitted, and (4) the documents seized during Nigro's lawful arrest were properly admitted. View "State v. Nigro" on Justia Law

Defendant Gary Gauthier Jr. and his co-defendant were each convicted of murder following a joint jury trial. After the Supreme Court affirmed their convictions, Gauthier filed a petition for post-conviction review, claiming he had been denied effective assistance of counsel at trial. The superior court denied Gauthier's petition, finding the strategy adopted by Gauthier's attorney did not rise to the level of ineffective assistance of counsel. On appeal, the Supreme Court affirmed, holding that the post-conviction court's findings were supported by competent record evidence and the court did not commit clear error in concluding that Gauthier failed to meet his burden of demonstrating ineffective assistance of counsel. View "Gauthier v. State" on Justia Law

Defendant Stanley Ward was convicted of kidnapping, attempted murder, and robbery and was sentenced to an aggregate sentence of fifty years, all but forty-five years suspended. Ward challenged the sentences on the grounds that (1) the length of the sentences, both individually and collectively, violated his constitutional protection against cruel or unusual punishment; (2) when the court found the facts necessary to impose consecutive sentences, resulting in a longer period of incarceration than the statutory maximum for any of his convictions individual, it violated his constitutional right to trial by jury; and (3) the court erred in its application of Me. Rev. Stat. 1256 in imposing consecutive sentences. The Supreme Court affirmed the judgment of the trial court, holding (1) Ward's collective and individual sentences did not constitute cruel or unusual punishment; (2) the superior court's imposition of consecutive sentences did not violate Ward's right to trial by jury; and (3) the superior court properly determined that the statute did not bar the imposition of consecutive sentences under these circumstances. View "State v. Ward" on Justia Law

Following a jury trial, appellant Michael Skarbinski was convicted on several counts, all of which arose from appellant's filing requests for tax refunds claiming no taxable income for three years when appellant had received substantial income. The supreme judicial court affirmed, holding (1) the court did not err when it instructed the jury on principles of tax law, and the court's instructions did not infringe upon the jury's role as fact-finder; (2) the court did not err in instructing the jury that if appellant believed the tax laws to be unconstitutional or illegal, or otherwise disagreed with them without an objectively reasonable good faith belief, his belief was not a defense to the charges; (3) the State's closing argument was not inflammatory and it did not improperly interject irrelevant issues into the case; and (4) the jury could have found each element of the offenses charged beyond a reasonable doubt, and the evidence was sufficient to support the convictions. View "State v. Skarbinski" on Justia Law

Defendant Philip Galarneau, III appealed his conviction as a âhabitual offenderâ for âoperating while under the influence.â In 2008, without a lawyer, Defendant pled not guilty to the charges in the district court. On the same day, an information containing the same charges was filed in the Superior Court where the State sought to revoke Defendantâs probation from a 2007 assault conviction. The district court charges were dismissed, and Defendant made his appearance at the probation revocation hearing at Superior Court. Defendant was appointed a lawyer-for-the-day. Defendantâs case was called, the court read the charges against him and asked both Defendant and his attorney whether he was advised of his rights. The court confirmed on record that Defendant waived his right to a trial, that he was pleading guilty to habitual offender and OUI charges, and that he admitted violating his probation. The Court sentenced Defendant to approximately two years for all the charges against him. On appeal to the Supreme Court, Defendant argued that his sentence and conviction were unconstitutionally imposed because the court did not inform Defendant of his right to counsel at the district court. The Supreme Court rejected that argument, finding that Defendant was represented by a lawyer-for-the-day during his initial appearance at Superior Court, and that the court confirmed Defendant was advised of his rights. The Court affirmed Defendantâs conviction and sentence.

âPenelope W.â appealed lower courtsâ decisions that involuntarily committed her to a state psychiatric center. In all aspects of her case, Penelope represented herself. The trial court concluded that she was mentally ill, and that she presented a likelihood of serious harm to herself and others. The appellate court denied Penelopeâs appeal because she failed to comply with the courtâs briefing requirements. On appeal to the Supreme Court, Penelope argued that she should not have been allowed to proceed at trial without counsel, particularly since involuntary commitment was at stake. The Supreme Court found although there is a limited right to self-representation in criminal cases, the same cannot be said for a civil commitment proceeding. The Court affirmed the trial courtâs decision that ordered Penelope to be committed.

Anthem Health Plans of Maine, Inc., appealed a judgment that affirmed a decision by the Superintendent of Insurance. The Superintendent determined that Anthemâs proposed average rate increase of 18.5% applicable to its individual health insurance products containing a built-in 3% profit margin was excessive and discriminatory. The Superintendent then indicated that an average 10.9% rate increase containing a 0% projected profit margin would be approved by his agency. Anthem contends that in setting a profit margin at 0%, the Superintendentâs decision eliminated Anthemâs opportunity to earn a reasonable profit. Anthem brought suit alleging the superintendentâs decision violates state law and the U.S. Constitution. The Supreme Court held (1) that because the year in which the challenged rates were effective has passed and new rates went into effect; (2) a favorable decision on the merits would not give Anthem any relief; and (3) because federal and state laws are in transition, there is no basis for the Court to address Anthemâs appeal from the Superintendent. The Court dismissed Anthemâs appeal as moot.