Justia Maine Supreme Court Opinion Summaries

Damion L. Butterfield was convicted of murder and other offenses after pleading guilty following a trial but before the jury announced its verdict. He sought to withdraw his guilty plea, arguing that the court abused its discretion by denying his request and his motion for a new trial. Butterfield also appealed his thirty-five-year prison sentence.The trial court (Cumberland County, MG Kennedy, J.) denied Butterfield's motion to withdraw his plea and his motion for a new trial. The court found that Butterfield had multiple opportunities to discuss his options with counsel and that his plea was made voluntarily and with full knowledge of the consequences. The court also noted that Butterfield did not assert his innocence and that the plea was entered after thorough colloquies. The court sentenced Butterfield to thirty-five years in prison, consistent with the joint recommendation of the parties.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the trial court did not abuse its discretion in denying Butterfield's motion to withdraw his plea, as the plea was made voluntarily and with full understanding of the consequences. The court also dismissed Butterfield's appeal of his sentence, noting that discretionary review is unavailable for sentences imposed pursuant to a joint recommendation of the parties. View "State of Maine v. Butterfield" on Justia Law

Raymond Ellis Jr. was convicted of robbery and possession of a firearm by a prohibited person. On August 5, 2023, Ellis, armed with a handgun, and a juvenile accomplice, armed with a sawed-off shotgun, robbed the Big Apple convenience store in Madison. They wore masks, threatened the store clerk, and stole cash from the registers. A third person acted as a lookout. Ellis was sentenced to twenty-five years for robbery, with all but twenty years suspended, and four years of probation, plus a concurrent three-year term for the firearm possession charge.The jury found Ellis guilty of robbery, criminal threatening with a dangerous weapon, and theft by unauthorized taking. The court found him guilty of possession of a firearm by a prohibited person after Ellis waived his right to a jury trial on that count. The court merged the criminal threatening and theft counts with the robbery count for sentencing purposes. Ellis appealed, arguing entitlement to a missing-witness jury instruction and errors in the sentencing process.The Maine Supreme Judicial Court reviewed the case. Ellis contended that the jury should have been instructed to infer that a missing witness would not have corroborated the State’s theory. The court reaffirmed its stance from State v. Brewer, holding that no such inference is permissible. The court also addressed Ellis’s claim of double-counting sentencing factors, noting that the sentencing court improperly considered Ellis’s failure to take responsibility as an aggravating factor. The court vacated Ellis’s sentence and remanded for resentencing, affirming the judgment of conviction in all other respects. View "State of Maine v. Ellis" on Justia Law

Rochelle Gleason was convicted of aggravated trafficking of a scheduled drug that caused the death of a person. In October 2021, Gleason communicated with the decedent about purchasing fentanyl and heroin. On October 16, 2021, the decedent bought drugs from Gleason, consumed them, and died of acute intoxication from fentanyl and kratom. The Maine Office of the Chief Medical Examiner sent a blood sample to a lab, where several employees conducted tests. A forensic toxicologist, Chelsea Deisher, reviewed the data and documentation and developed a toxicology report indicating the presence of fentanyl and kratom in the decedent’s blood.The State charged Gleason on September 28, 2022, and she pleaded not guilty. During the trial, Deisher testified about the test results, although she did not conduct the tests herself. Gleason objected, arguing that her Sixth Amendment right to confront the witnesses against her was violated because she could not cross-examine the actual testers. The trial court allowed Deisher’s testimony, and the jury found Gleason guilty. She was sentenced to eighteen years in prison, with all but eight years suspended, and four years of probation. Gleason appealed the conviction.The Maine Supreme Judicial Court reviewed the case, focusing on the Confrontation Clause issue. The court noted that the U.S. Supreme Court’s decision in Smith v. Arizona, issued during the appeal, rejected the rationale that allowed experts to testify based on out-of-court statements not admitted for their truth. The court found that Deisher’s testimony relied on the truth of the data and documentation generated by others, which Gleason could not cross-examine. The court vacated the judgment and remanded the case for a new trial to determine whether the statements relied upon by Deisher were testimonial. View "State of Maine v. Gleason" on Justia Law

Aaron A. Robshaw was convicted by a jury in the Penobscot County Unified Criminal Docket for gross sexual assault (Class A), unlawful sexual contact (Class A), and unlawful sexual contact (Class B) against a minor. The incidents occurred in 2018 and 2019 when the victim was ten and eleven years old. The victim disclosed the abuse to her mother in 2019 and fully revealed the extent of the abuse four years later. During the trial, the State presented expert testimony on child victims' delayed disclosure of sexual abuse, which Robshaw objected to, arguing it would improperly bolster the victim's credibility.The trial court allowed the expert testimony, and after the State rested its case, the court granted Robshaw’s motion for judgment of acquittal on one count of gross sexual assault. The jury found Robshaw guilty on the remaining counts. The court sentenced Robshaw to twenty years' imprisonment followed by twenty years of supervised release. Robshaw appealed the conviction and sentence, arguing improper admission of expert testimony, misapplication of the law in sentencing, and abuse of discretion in imposing supervised release.The Maine Supreme Judicial Court reviewed the case. The court held that the trial court did not abuse its discretion in admitting the expert testimony, as it was limited to general information about delayed disclosure and did not directly bolster the victim's credibility. The court also found that the trial court properly applied the sentencing analysis, setting the basic term of imprisonment at the legislatively mandated minimum of twenty years and considering aggravating and mitigating factors. The court further held that the trial court did not abuse its discretion in imposing a twenty-year period of supervised release, as it appropriately considered the need to protect the public and Robshaw’s history of sexual offenses. The Maine Supreme Judicial Court affirmed the judgment, sentence, and period of supervised release. View "State of Maine v. Robshaw" on Justia Law

Heath G. Demerchant was convicted of domestic violence assault (Class C) after a jury trial. The incident involved Demerchant grabbing his wife's throat and hitting her during an argument about a debit card. The State presented testimony from the victim, witnesses, and police officers. Demerchant argued that his actions were justified under the competing harms justification, claiming he was preventing imminent harm to another person.The trial court denied Demerchant's request for a jury instruction on the competing harms justification, finding insufficient evidence of imminent physical harm to another. The jury found Demerchant guilty, and he was sentenced to five years in prison, with all but three years suspended, and four years of probation.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that there was no evidence of a specific and imminent threat of physical harm to justify the competing harms instruction. The court emphasized that the justification requires evidence of an imminent threat, which was not present in this case. Therefore, the trial court did not err in denying the requested jury instruction. View "State of Maine v. Demerchant" on Justia Law

Jarae Lipscombe was convicted by a jury of hindering apprehension or prosecution (Class B) for actions taken to delay or prevent the apprehension of his brother, who was later charged with homicide in Waterville. Lipscombe provided false information to the police and assisted his brother in avoiding capture. Five months after his conviction, Lipscombe moved for a new trial, arguing that his brother's acquittal of murder would likely lead to a different outcome in his own case. The trial court denied the motion, and Lipscombe appealed.The Kennebec County trial court held a three-day jury trial where Lipscombe's defense focused on his lack of knowledge regarding his brother's involvement in the homicide. The State presented evidence showing that Lipscombe gave a false description to the police, knew the police were seeking his brother, and made arrangements for his brother to stay at a friend's house. Additionally, Lipscombe confessed to witnessing his brother shoot the victim and offered money to retrieve the weapon. After the jury found Lipscombe guilty, he appealed the judgment, which was affirmed by the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed Lipscombe's appeal of the trial court's denial of his motion for a new trial. The court held that the acquittal of Lipscombe's brother was irrelevant to Lipscombe's conviction. The court explained that the statute defining hindering apprehension or prosecution does not require proof of the brother's guilt but rather that Lipscombe knew of his brother's conduct that could render him liable to a charge of murder. The court affirmed the judgment, concluding that the brother's acquittal did not change the factual circumstances of the conduct Lipscombe witnessed. View "State of Maine v. Lipscombe" on Justia Law

Matthew W. Pendleton was convicted of manslaughter after a jury trial. Pendleton and the victim, Kevin Curit, were childhood friends, and Curit had moved into Pendleton's home. On January 5, 2023, Pendleton bought alcohol, and later that night, he sent text messages to his daughter, including photos of Curit lying unconscious and statements about injuring his hands. The next morning, Pendleton texted his estranged wife that Curit was dead and later called 9-1-1. The police found Curit dead in a camper with multiple injuries, and the medical examiner concluded that Curit died of strangulation by ligature.The Waldo County trial court admitted screenshots of Pendleton's text messages and his daughter's testimony about his alcohol use and their family dynamic. The court also allowed a jailhouse informant to testify but struck the testimony and instructed the jury to disregard it after the informant mentioned meeting Pendleton in jail. Pendleton was found guilty of manslaughter and sentenced to twenty years in prison, with all but fourteen years suspended, followed by four years of probation.Pendleton appealed to the Maine Supreme Judicial Court, challenging the admission of the text messages and his daughter's testimony, the handling of the jailhouse informant's testimony, and the court's refusal to consider a juror's affidavit during sentencing. The court affirmed the conviction and sentence, finding no abuse of discretion in the trial court's rulings. The court held that the text messages were relevant and not unfairly prejudicial, the daughter's testimony was admissible, the curative measures for the informant's testimony were sufficient, and the juror's affidavit was properly excluded from sentencing considerations. View "State of Maine v. Pendleton" on Justia Law

Clifton Thomas was convicted of two counts of aggravated trafficking of scheduled drugs and one count of criminal forfeiture of property. The charges stemmed from a search of an apartment where Thomas was staying, which uncovered drugs, drug paraphernalia, and a firearm. The search was conducted pursuant to a warrant obtained after Thomas was involved in a domestic violence incident. Thomas challenged the search, arguing that the warrant lacked probable cause for drug-related items and that the evidence was not in plain view.The trial court denied Thomas's motions to suppress the evidence, finding that the search warrant was valid for firearms and a cell phone, and that the drugs were discovered in plain view during a lawful search. The court also denied Thomas's discovery motions regarding missing surveillance video, cell phones, and a coat, concluding that the State did not act in bad faith and that the evidence did not have apparent exculpatory value. Additionally, the court allowed a new chemist to testify about the drug analysis, despite the original chemist not testifying.The Maine Supreme Judicial Court reviewed the case and found that Thomas's confrontation rights were violated by the admission of the new chemist's testimony, which relied on the original chemist's notes and data. The court determined that this violation was not harmless, as the chemist's testimony was crucial to establishing the weight of the drugs, a key element of the charges. Consequently, the court vacated Thomas's conviction and remanded the case for further proceedings. View "State of Maine v. Thomas" on Justia Law

Craig A. Woodard was convicted of elevated aggravated assault, aggravated assault, and assault after a jury trial. The trial court found that the offense of elevated aggravated assault was committed with the use of a firearm and imposed a mandatory minimum sentence of four years’ imprisonment. The court merged the offenses and sentenced Woodard to twelve years’ imprisonment with all but five years suspended and three years of probation. Woodard appealed, arguing that the court erred in failing to give jury instructions regarding defense of another and in applying the mandatory minimum sentence for a Class A offense committed with a firearm. He also contended that the court improperly considered his age and lack of remorse as aggravating factors.The trial court (Hancock County, Larson, J.) denied Woodard’s motion for a judgment of acquittal and sentenced him as described. Woodard’s appeal was consolidated with his sentence review appeal, which was granted by the Sentence Review Panel.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s judgment and sentence. The court held that Woodard waived the issue of jury instructions regarding defense of another by not requesting them at trial and agreeing with his counsel’s strategy. The court also found that the indictment sufficiently alleged the use of a firearm, justifying the mandatory minimum sentence. Additionally, the court ruled that considering Woodard’s age and lack of remorse as aggravating factors was within the trial court’s discretion and did not constitute an abuse of discretion. View "State of Maine v. Woodard" on Justia Law

Abdihamit A. Ali was convicted of elevated aggravated assault, reckless conduct with a dangerous weapon, possession of a firearm by a prohibited person, and criminal mischief following a jury trial in the Cumberland County Unified Criminal Docket. The court sentenced him to fifteen years, with all but seven years suspended, and four years of probation for the elevated aggravated assault charge, with concurrent sentences for the other charges. Ali appealed, arguing that the trial court improperly admitted hearsay testimony and failed to merge his convictions for elevated aggravated assault and reckless conduct with a dangerous weapon.The trial court admitted testimony from a detective about statements made by Ali’s mother to other officers, which Ali argued was hearsay. The court overruled Ali’s objection, and the jury found him guilty on three counts, while the court found him guilty on the fourth count. Ali was sentenced accordingly and appealed the decision.The Maine Supreme Judicial Court reviewed the case and agreed that the hearsay testimony should not have been admitted without a limiting instruction. However, the court found this error to be harmless given the substantial evidence against Ali. The court also agreed with Ali that his convictions for elevated aggravated assault and reckless conduct with a dangerous weapon should have been merged, as they did not each require proof of an additional fact and could have been based on the same conduct. Consequently, the court vacated the sentence and remanded the case for resentencing, merging the two convictions. The judgment was affirmed in all other respects. View "State of Maine v. Ali" on Justia Law