Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment entered by the superior court denying in part Petitioner's petition for post-conviction review of his conviction on several sexual assault charges, holding that Petitioner was deprived of his right to the effective assistance of trial counsel.After a trial, the jury found Petitioner guilty of one count each of gross sexual assault, unlawful sexual contact, and sexual abuse of a minor. The Supreme Court affirmed. Petitioner subsequently filed a postconviction petition arguing that he had been deprived of his right to the effective assistance of counsel. The Supreme Court granted the petition as to the convictions for unlawful sexual contact and sexual abuse of a minor and vacated Petitioner's convictions on those counts but denied Petitioner's petition as to the conviction for gross sexual assault. The Supreme Judicial Court vacated the judgment and remanded for entry of a judgment granting Petitioner's petition for post-conviction review and vacating the remaining conviction, holding that counsel's performance was deficient and that Petitioner was entitled to post-conviction relief from the remaining portion of the judgment of conviction. View "Hodgdon v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the Department of Public Safety's denial of Appellant's application for a professional investigator license, holding that Appellant's First Amendment rights were not violated by the application of statutory competency standards to his conduct on social media.The Department denied Appellant's application based on comments and posts that he had made on social media using an account bearing the name of his out-of-state private investigation business concerning a police lieutenant. The Supreme Judicial Court affirmed the circuit court's affirmation of the Department's decision, holding (1) intermediate scrutiny applies to the Department's application of the licensing statutes to Appellant's application; (2) the Department did not err in its findings; and (3) the Department's application of the licensing standards to Appellant did not violate the First Amendment. View "Gray v. Department of Public Safety" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of possession of sexually explicit material, holding that the superior court did not err by denying Defendant's motion to suppress on the grounds that Defendant, despite his diagnosis of Autism Spectrum Disorder (ASD), was capable of voluntary consent.Defendant sought to suppress his statements to police regarding sexually explicit material depicting minors found on his electronic tablet and any evidence of sexually explicit materials depicting minors discovered as a result. The superior court denied Defendant's motion to suppress, concluding that Defendant had the capacity to and did voluntarily speak to the police and consent to the search of his tablet. The Supreme Judicial Court affirmed, holding that Defendant's ASD did not render his statements or the search of his tablet involuntary. View "State v. Glenn" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of domestic violence assault, holding that Defendant was not prejudiced.On appeal, Defendant argued (1) the trial court erred by allowing testimony from Defendant's fifteen-year-old daughter concerning Defendant's parenting practices, and (2) the State committed prosecutorial misconduct by commenting on admissible evidence during its cross-examination of her. The Supreme Judicial Court affirmed, holding (1) because, in her opening statement, Defendant indicated her pursuit of the parental discipline justification found at Me. Rev. Stat. 17-A, 106(1), the court did not err in admitting evidence of Defendant's parenting; and (2) the State committed prosecutorial conduct by eliciting and commenting on evidence that other children had been removed from Defendant's home, but the error was not so prejudicial that it affected the outcome of the proceeding. View "State v. Pratt" on Justia Law

The Supreme Judicial Court affirmed the interlocutory order of the superior court denying Defendant's motion to dismiss on double jeopardy grounds a superseding indictment against him, holding that neither the United States Double Jeopardy Clause nor its counterpart in the Maine Constitution barred the State from retrying Defendant on the superseding indictment.On appeal, Defendant argued that the superior court erred in denying his motion to dismiss because the dismissal of the original indictment against him after the jury was empaneled and sworn barred the State from charging him twice with the same offense. The Supreme Judicial Court clarified the implications of a defective indictment for purposes of the Double Jeopardy Clauses of the state and federal Constitutions and affirmed, holding (1) jeopardy attached in Defendant's trial; but (2) the trial court's dismissal of the indictment was not the equivalent of an acquittal and did not bar retrial. View "State v. Shirey" on Justia Law

In this action brought by Plaintiff, an inmate, the Supreme Judicial Court vacated the portions of the superior court's judgment denying injunctive relief, restoring good-time credit for the period of Plaintiff's nondisciplinary segregation, and entering judgment for Defendants on Plaintiff's 42 U.S.C.S. 1983 claim, holding that restoration of Plaintiff's "good time" was not an available remedy through judicial review of the Department's disciplinary action against Plaintiff and that the Maine Constitution's mandate regarding separation of powers does not preclude an award of injunctive relief on a section 1983 claim against the Department of Corrections.Plaintiff filed a complaint seeking judicial review of a disciplinary decision of the Department and injunction for violations of his civil rights. The superior court vacated the disciplinary decision but concluded that it was prohibited from entering injunctive relief on the section 1983 claim. The court then restored good-time credit for the period of nondisciplinary segregation as a remedy for Plaintiff's Rule 80C claim and entered judgment for Defendants on the section 1983 claim. The Supreme Judicial Court vacated the judgment in part and remanded for the court to determine whether injunctive relief should be awarded, enter judgment in Plaintiff's favor on his section 1983 claim and ordered the restoration of good-time credit for the period of Plaintiff's nondisciplinary segregation as a remedy for the constitutional violations alleged in his section 1983 claim. View "Burr v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder of a deputy sheriff, holding that there was no error, clear or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in permitting the State to introduce in-court demonstrations of the possible circumstances of the shooting and in allowing the demonstration to be presented to the jury over Defendant's Rule 403 objection; (2) the trial court did not err in partially denying Defendant's motion to suppress statements he made to detectives after his arrest; and (3) there was no error in the court's sentencing proceedings, and the court did not abuse its discretion in imposing a sentence of life imprisonment. View "State v. Williams" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for trafficking in prison contraband, unlawful possession of a scheduled drug, and violating a condition of release, holding that the trial court erred in its handling of the void dire process and in admitting certain evidence.On appeal, Defendant argued that the trial court abused its discretion when it denied his race-related voir dire questions and erred in partially denying his motion to suppress statements he made to a corrections officer upon his arrival to jail after his arrest. The Supreme Judicial Court agreed, holding (1) the voir dire process was not sufficient to disclose facts that would reveal juror bias; and (2) the trial court erred in denying Defendant's motion to suppress, and the error was not harmless. View "State v. Fleming" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court vacating the Secretary of State's determination that an inadequate number of valid signatures had been submitted to place on the ballot a people's veto of An Act to Implement Ranked-choice Voting for Presidential Primary and General Elections in Maine, holding that the superior court erred in concluding that Petitioner had satisfied his burden of overcoming the presumption of constitutionality.Upon a petition for review of the Secretary of State's decision, the superior court determined that it was unconstitutional for the State to require that every circulator who collected signatures be registered to vote in the circulator's municipality of residence. The Supreme Court reversed, holding that Petitioner failed to demonstrate that the constitutional and statutory requirement that a circulator be a registered voter in the circulator's municipality of residence when collecting signatures violates the First Amendment. The Court remanded the cause with instructions to affirm the Secretary of State's determinations that the signatures contested on appeal were invalid and that an inadequate number of valid signatures had been submitted to place the people's veto on the ballot. View "Jones v. Secretary of State" on Justia Law

The Supreme Judicial Court accepted a report from the superior court submitting three questions of law concerning a people's veto effort seeking to suspend P.L. 2019, ch. 539 - entitled "An Act To Implement Ranked-choice Voting for Presidential Primary and General Elections in Maine" - through the November 2020 general election, answered the questions, and remanded the matter to the superior court for further proceedings.Specifically, the Supreme Judicial Court answered (1) the Second Regular Session of the 129th Legislature served as the “session of the Legislature in which [L.D. 1083] was passed,” Me. Const. art. IV, pt. 3, 16-17; (2) Public Law 2019, ch. 539, was set to become effective on June 15, 2020, “90 days after the recess of” the Second Regular Session and was suspended upon the filing of the people’s veto petition; and (3) Title 21-A Me. Rev. Stat. 901(1) sets only an end date for the filing of applications for a people’s veto and not a starting cutoff that would prohibit the early filing of an application prior to the Legislature’s adjournment. View "Payne v. Secretary of State" on Justia Law