Justia Maine Supreme Court Opinion Summaries

The case concerns an individual who engaged in a lengthy, high-speed police chase that began after a domestic dispute in Brunswick, Cumberland County. The individual left in his girlfriend’s car without permission and was soon pursued by police, first in Sagadahoc County and then back and forth between Sagadahoc and Cumberland Counties. Throughout the chase, he drove recklessly, endangered other drivers, and ultimately collided with a police cruiser, injuring an officer. The entire pursuit was captured on video and presented at trial.A criminal complaint was filed, and a Cumberland County grand jury indicted him on several charges, including eluding an officer and reckless conduct with a dangerous weapon. After it was discovered that some conduct occurred in Sagadahoc County, the State successfully moved to amend the indictment to include both counties. The trial court, sitting as the Cumberland County Unified Criminal Docket, denied the defendant’s motion for acquittal, and the jury found him guilty of eluding an officer and reckless conduct with a dangerous weapon. He was acquitted of some other charges, and this appeal followed.The Maine Supreme Judicial Court reviewed whether the Cumberland County grand jury had the authority to indict for conduct spanning both counties and whether the evidence supported the conviction for reckless conduct with a dangerous weapon. The Court held that both crimes were continuing offenses, committed in both counties, and could be indicted in either. The Court also held that the evidence was sufficient for the jury to find that the defendant used his vehicle as a dangerous weapon. The judgment of conviction was affirmed. View "State of Maine v. Coffill" on Justia Law

Keith Merchant was indicted on eight charges related to repeated sexual offenses against his niece, which occurred over several years beginning when she was twelve years old. The offenses included two counts of gross sexual assault, three counts of unlawful sexual contact, two counts of sexual abuse of a minor, and one count of violating a condition of release. Merchant pleaded guilty to all charges. At sentencing, the court considered testimony from law enforcement and unsworn statements from the victim and her family, noting the lengthy period of abuse and Merchant’s position of trust.The Somerset County Unified Criminal Docket accepted Merchant’s guilty pleas and conducted sentencing in accordance with the three-step analysis established in State v. Hewey and codified in Maine law. The court imposed twenty years’ imprisonment for the first gross sexual assault count and a consecutive ten-year sentence, plus ten years of supervised release, for the second gross sexual assault count. The remaining sentences were set to run concurrently with the first count. Merchant filed for, and was granted, leave to appeal his sentence by the Sentence Review Panel.The Maine Supreme Judicial Court reviewed the case and determined that the sentencing court erred by applying the same sentencing analysis to both primary gross sexual assault counts but issuing different sentences for each, without providing a logical or articulated basis for the disparity. The Court held that a separate, individualized sentencing analysis was required for each primary count that was to run consecutively. Consequently, the Court vacated Merchant’s sentence and remanded the case for resentencing in accordance with its opinion, specifying that no more severe sentence could be imposed on remand. View "State of Maine v. Merchant" on Justia Law

Law enforcement arrested an individual for operating under the influence after stopping him and bringing him to the police station. At the station, the officer explained the consequences of refusing a breath test, including administrative penalties and possible jail if the individual refused. After discussion and clarification that no additional charges would result from refusal, the individual agreed to take the breath test, although he initially stated he did not consent. The breath test was administered, and the individual was subsequently charged with criminal operating under the influence.The individual moved to suppress the breath test results in the Penobscot County Unified Criminal Docket, arguing that his consent to the test was not voluntary due to the officer’s statements and actions. The trial court denied the motion, citing Birchfield v. North Dakota, which held that warrantless breath tests incident to arrest do not require consent under the Fourth Amendment. After this ruling, the individual entered a conditional guilty plea, preserving his right to challenge the suppression ruling on appeal.The Supreme Judicial Court of Maine reviewed the case. The court held that, under Birchfield v. North Dakota, the Fourth Amendment allows warrantless breath tests as searches incident to arrest, and thus, the individual's consent was immaterial to the test’s admissibility. The court further concluded that the officer’s actions did not render the search unreasonable, as there were no false statements or arbitrary conduct, and the incentives provided by the officer were permissible. The court also held that the challenge must be analyzed under the Fourth Amendment rather than the Fourteenth Amendment’s Due Process Clause. Accordingly, the judgment was affirmed. View "State of Maine v. Davis" on Justia Law

The case involves the conviction of a defendant for murder following the stabbing death of Kimberly Neptune, who was found in her apartment with 484 sharp force injuries. The defendant, Kailie Brackett, and a co-defendant, Donnell Dana, Jr., were indicted for intentional, knowing, or depraved indifference murder. The prosecution presented evidence including surveillance footage, testimony from witnesses about Brackett’s relationship with the victim and usage of the victim’s bank card, as well as forensic evidence from the crime scene. Notably, the prosecution relied on expert testimony comparing partial, sock-clad bloody footprints found at the scene to prints taken from Brackett in prison.The Washington County Unified Criminal Docket conducted the jury trial. Brackett objected to the admission of the forensic podiatry evidence, arguing it lacked scientific reliability. The trial court admitted the expert testimony over her objections, and the jury ultimately found Brackett guilty, but deadlocked as to Dana. Brackett was sentenced to fifty-five years in prison and appealed her conviction and sentence, challenging the sufficiency of the evidence, admission of the expert testimony, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court erred in admitting the forensic podiatry testimony comparing the partial, sock-clad footprints. The expert’s methodology lacked scientific reliability and was not sufficiently grounded in recognized standards, and the prosecutor’s closing arguments improperly characterized this evidence as definitive proof of Brackett’s presence at the scene. Because this error was likely to have affected the jury’s verdict, the Court vacated Brackett’s conviction and remanded for a new trial, holding that the State may retry Brackett but must exclude the challenged footprint comparison testimony. View "State of Maine v. Brackett" on Justia Law

In 1996, a series of crimes including gross sexual assault and burglary were committed in Hancock County, Maine. The State filed a criminal complaint in August 2002, just before the statute of limitations was set to expire, naming the accused as “John Doe #1, Unknown Male with Matching Deoxyribonucleic Acid (DNA) Profile at 13 Genetic Locations.” An arrest warrant based on the DNA profile was issued. For the next twenty years, advancements in forensic genetic genealogy eventually enabled law enforcement to identify Jason J. Follette as the suspect. In November 2022, the State amended the complaint to specifically name Follette and charged him with the same offenses. Follette was arrested, appeared in court, and was released on bail.The case was reviewed by the Maine District Court in Hancock County. Follette filed several pretrial motions, including the motion to dismiss at issue here, arguing that (1) the State’s prosecution was barred because he was not specifically named in the initial complaint within the statute of limitations, and (2) the lengthy delay violated his Sixth Amendment right to a speedy trial. After a hearing, the court denied the motion, finding that the 2002 complaint tolled the statute of limitations and that his speedy trial rights were not violated.On appeal, the Maine Supreme Judicial Court considered Follette’s arguments but ultimately concluded that the appeal was interlocutory, as it sought review of a pretrial order denying a motion to dismiss. The court determined that none of the recognized exceptions to Maine’s final judgment rule applied, including the judicial economy, death knell, or collateral order exceptions. As a result, the court dismissed the appeal for lack of a final judgment, holding that review of the statute of limitations and speedy trial claims must await final resolution of the case. View "State of Maine v. Follette" on Justia Law

Aaron Aldrich was convicted of two counts of intentional or knowing murder and possession of a firearm by a prohibited person. The evidence at trial showed that Aldrich went to a trailer in Poland, Maine, carrying a nine-millimeter rifle. He entered the trailer, shot both an adult and a teenager multiple times, and took a handgun and cash before leaving. Afterward, Aldrich told his friend he had killed the residents and instructed his girlfriend to dispose of evidence. The police later found forensic evidence linking Aldrich to the crime scene and recovered the murder weapon. He was apprehended in New Hampshire after fleeing in a stolen van.The Androscoggin County Unified Criminal Docket conducted a jury trial. Aldrich moved to suppress his post-arrest statements, claiming Miranda violations and improper questioning after requesting counsel; this motion was denied after an evidentiary hearing. The trial court made several evidentiary rulings, including admitting images of the victims, evidence of Aldrich’s theft and flight, testimony about his prior acts, and limiting cross-examination of witnesses. Aldrich testified, claiming self-defense. The jury found him guilty on all counts. He was sentenced to concurrent life terms for the murder convictions and five years for the firearm-possession count. Aldrich appealed both his convictions and sentences, arguing errors in suppression, evidentiary rulings, jury instructions, and sentencing analysis.The Maine Supreme Judicial Court reviewed all claims. The court held that the denial of the motion to suppress was correct because Aldrich was not subjected to custodial interrogation under Miranda. Most evidentiary rulings were proper; the few errors identified, including admission of hearsay and exclusion of certain defense evidence, were harmless and did not cumulatively deprive Aldrich of a fair trial. The jury instructions and sentencing analysis were found to be legally sound. The court affirmed the convictions and sentences. View "State of Maine v. Aldrich" on Justia Law

Between 2019 and 2022, a bookkeeper for a family-owned machine and fabrication business misappropriated approximately $500,000 from her employer. She forged the co-owner’s signature on checks made out to herself and later confessed to the theft in a video-recorded interview with law enforcement. The bookkeeper admitted to taking funds for personal use and acknowledged the significant amount taken. She was charged with theft by unauthorized taking or transfer and forgery, pleaded not guilty, and proceeded to a jury trial.Prior to trial, the defendant sought access to the company’s QuickBooks password through a motion to compel discovery, which she later withdrew. She subsequently moved to suppress her confession as involuntary, but the Unified Criminal Docket (Piscataquis County, Roberts, J.) denied the motion after a hearing. Additional pretrial motions included a request for the trial judge’s recusal, based on his prior professional association with the prosecutor, and a motion to exclude financial evidence due to the State’s failure to produce the QuickBooks password. Both motions were denied. At trial, the prosecution presented testimonial, documentary, and video evidence, including the defendant’s confession. The jury found her guilty on both counts, and she was sentenced to concurrent prison terms, with part of the sentence suspended and probation imposed.On appeal, the Maine Supreme Judicial Court reviewed claims of prosecutorial error, denial of recusal, and alleged discovery violations. The Court held that although some prosecutorial statements constituted error, these were harmless in light of overwhelming evidence of guilt, including the defendant’s own confession. The Court also found no abuse of discretion in denying recusal or in rulings regarding discovery, concluding the State was not obligated to produce information it did not possess. The conviction was affirmed. View "State of Maine v. Moulton" on Justia Law

Daniel Gantnier was convicted by a jury in 2006 of unlawful sexual contact, a sex offense that, under Maine law at the time, required lifetime registration as a sex offender. However, when the court imposed his sentence in 2007, the judgment and commitment form mistakenly indicated that he was obligated to register for only ten years instead of life. After Gantnier completed the ten-year term, the State Bureau of Identification reviewed his case, identified the error, and in 2019 notified him that his registration requirement was corrected to require lifetime registration. Gantnier did not comply with this requirement, and in 2022 the State charged him with failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999).Following his not guilty plea, Gantnier moved to dismiss the complaint in the trial court (Kennebec County), arguing that retroactively imposing a lifetime registration requirement violated the Ex Post Facto Clause of the United States Constitution and that the State’s correction should have been pursued under Rule 35(a), which governs correction of illegal sentences. The trial court (Daniel Mitchell, J.) denied his motion, finding that, due to a 2004 legislative amendment, SORNA of 1999 registration was not part of a criminal sentence for offenses like Gantnier’s. The court found that the correction was regulatory, not punitive, and thus not subject to ex post facto protections. After his motion for reconsideration was also denied, Gantnier entered a conditional guilty plea, reserving his right to appeal.On appeal, the Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that because Gantnier’s registration requirement was not part of his sentence, the retroactive correction to lifetime registration did not violate the Ex Post Facto Clause. The Court also determined that the State acted properly under 34-A M.R.S. § 11222(1), and was not required to proceed under Rule 35(a). The judgment was affirmed. View "State of Maine v. Gantnier" on Justia Law

On June 15, 2021, two individuals in Portland, Maine reported being struck from behind by a man who inflicted a sharp pain, with one sustaining a wound on her back. The assailant was described as an African-American male with short spiky hair, wearing a green shirt, and carrying a backpack and tablet. Police identified Saad Zackaria as the likely suspect and located him at the Preble Street Resource Center, where staff permitted officers to enter. Zackaria was found fully dressed near the shower room; after he reentered the shower room with the door partially open, officers observed various sharp objects on the floor, including tweezers, a box cutter, and a wire. Zackaria was subsequently arrested.Following his arrest, Zackaria was charged in June 2021 and indicted in August. The Cumberland County Unified Criminal Docket found him incompetent to stand trial in August 2021, but competency was restored in March 2022. Pretrial motions, including a motion to suppress evidence, were denied after a hearing. Delays arose from counsel withdrawal, attorney illness, and a mistrial due to juror unavailability. Zackaria filed motions to dismiss for delay and for a new bail hearing, both denied in early January 2024. After a jury trial in January 2024, Zackaria was found guilty of aggravated assault with a dangerous weapon and two counts of assault with a dangerous weapon and received a sentence including incarceration and probation.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that Zackaria did not have an objectively reasonable expectation of privacy in the shower room or common area of the shelter under the Fourth Amendment, due to the circumstances of his use and the openness of the space. Additionally, the Court found no abuse of discretion in the trial court’s denial of the speedy trial claim, noting that most delays were not attributable to the State or Zackaria, and that the lengthy pretrial detention did not prejudice the defense. View "State of Maine v. Zackaria" on Justia Law

Denis Lemieux pleaded guilty to domestic violence terrorizing and received a partially suspended sentence with probation. The probation terms required that he not contact certain family members, refrain from criminal conduct, seek evaluations and counseling, and notify probation before moving. Several months later, the State alleged that Lemieux violated his probation by making threatening social media statements about two family members he was barred from contacting, failing to comply with required evaluations and counseling, and not notifying probation of a move.The Kennebec County Unified Criminal Docket held a hearing, found by a preponderance of the evidence that Lemieux violated multiple probation conditions, and partially revoked his probation, imposing a custodial sanction. Lemieux argued at the sanction hearing that the court should consider the constitutionality of the statute under which he was convicted, asserting that if the statute was unconstitutional, his conviction and sentence were void. The court rejected this collateral attack, concluding that only a post-conviction review proceeding—not a probation revocation hearing—was the proper procedure for challenging the validity of the underlying conviction. Lemieux’s post-conviction review petition raising the constitutional issue had been stayed pending appeal.The Maine Supreme Judicial Court reviewed the case. It held that a defendant may not use a probation revocation proceeding to collaterally attack the constitutionality of the statute underlying the conviction. The court reaffirmed that post-conviction review is the exclusive method for challenging the validity of a conviction, except for direct appeal. The decision to affirm the trial court’s revocation of Lemieux’s probation was based on the proper use of procedural avenues for contesting convictions. The judgment of probation revocation was affirmed. View "State of Maine v. Lemieux" on Justia Law