Justia Maine Supreme Court Opinion Summaries

Julio Cesar Hernandez-Rodriguez was convicted of two drug offenses after a trial court denied his motion to suppress statements made to Maine Drug Enforcement Agency (MDEA) agents. Hernandez-Rodriguez argued that his statements to one agent should be suppressed because he was subject to unwarned custodial interrogation and that his statements to another agent should be suppressed due to his limited English proficiency, which he claimed prevented him from making a knowing and voluntary waiver of his rights.The trial court found that Hernandez-Rodriguez was in custody during his interactions with the agents and that he had not waived his Miranda rights while speaking with the first agent. However, the court concluded that his statements to the first agent were admissible because they were not the product of interrogation. The court also found that Hernandez-Rodriguez had knowingly and voluntarily waived his Miranda rights when speaking with the second agent, despite his limited English proficiency. Hernandez-Rodriguez entered a conditional guilty plea, preserving his right to appeal the suppression rulings.The Maine Supreme Judicial Court reviewed the case and determined that the trial court erred in not suppressing Hernandez-Rodriguez’s statement identifying a substance as cocaine in response to the first agent’s question, as it was the product of custodial interrogation. However, the court upheld the trial court’s finding that Hernandez-Rodriguez had validly waived his Miranda rights when speaking with the second agent. Given the error in admitting the statement about the cocaine, the court vacated the judgment and remanded the case, allowing Hernandez-Rodriguez the opportunity to withdraw his plea. View "State of Maine v. Hernandez-Rodriguez" on Justia Law

Richard W. Kelley was convicted of aggravated trafficking of scheduled drugs after a stop and search of a friend's vehicle in which he was a passenger. Law enforcement conducted the search as part of an investigation into the vehicle's owner for drug trafficking, using a search warrant and two tracking warrants to monitor the vehicle's location. Kelley moved to suppress the evidence obtained through the warrants, arguing that he had a reasonable expectation of privacy in the vehicle.The trial court (Penobscot County, A. Murray, J.) denied Kelley's motion to suppress on the grounds that he lacked standing to challenge the search. Kelley argued that the court should not have addressed his standing because the State had stipulated that he had a reasonable expectation of privacy in the vehicle. However, the court concluded that standing is a threshold issue that must be addressed regardless of the State's stipulation. Kelley was subsequently convicted based on his conditional guilty plea.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the State's stipulation regarding Kelley's standing was not binding on the court. The court further held that Kelley lacked a reasonable expectation of privacy in the vehicle, as he did not have a property or possessory interest in it, nor did he have an interest in the property seized. Therefore, Kelley did not have standing to challenge the search warrants. The judgment of conviction was affirmed. View "State of Maine v. Kelley" on Justia Law

Billy L. Beaulieu was charged with criminal OUI (Class C) under Maine law. He filed a motion to dismiss the charges, claiming immunity under Maine’s Good Samaritan statute, which provides immunity from prosecution if a call for assistance for a suspected drug-related overdose is made at the location of a medical emergency. Beaulieu argued that the statute’s requirements were met because a driver who saw his car beside an interstate highway exit asked the police to check on the vehicle, suspecting a medical event.The Cumberland County trial court denied Beaulieu’s motion to dismiss. The court found that the witness was concerned about a medical event and reported it to the police, who then checked on Beaulieu. However, the court concluded that the situation did not meet the statutory requirements for immunity because the call was not for a suspected drug-related overdose, and there was no medical emergency.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the Good Samaritan statute’s plain language requires the call for assistance to be specifically for a suspected drug-related overdose and that the location must be a medical emergency. The court found that the witness’s concern about a general medical event did not satisfy the statute’s requirements. Additionally, there was no evidence of a medical emergency at the scene. Therefore, Beaulieu was not entitled to immunity under the Good Samaritan statute, and the denial of his motion to dismiss was affirmed. View "State of Maine v. Beaulieu" on Justia Law

Dennis W. Lowery was convicted of gross sexual assault after a jury trial in Cumberland County. The incident occurred on December 19, 2021, when Lowery entered the victim's room at a Portland inn without her knowledge or permission and sexually assaulted her while she was asleep. The victim identified Lowery to the police, who found him nearby. DNA evidence linked Lowery to the crime.The trial court denied Lowery's motions to dismiss and for a new trial, which were based on alleged discovery violations by the State. Lowery argued that the State failed to disclose information about certain witnesses and evidence handlers in a timely manner. The court allowed the testimony of these witnesses, reasoning that Lowery was aware of their roles and had the opportunity to cross-examine them. The court also denied Lowery's motion for a judgment of acquittal on the gross sexual assault charge but granted it on a burglary charge due to a defect in the indictment.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decisions. The court held that the trial court did not abuse its discretion in handling the alleged discovery violations, as Lowery was not prejudiced to the extent that it deprived him of a fair trial. The court also found no obvious error in the admission of evidence regarding Lowery's pre-arrest silence, as Lowery did not invoke his right to remain silent before being questioned by the police. The court concluded that the trial court's actions were appropriate and did not violate Lowery's due process rights. View "State of Maine v. Lowery" on Justia Law

Richard W. Kelley was convicted of aggravated trafficking of scheduled drugs after a stop and search of a friend's vehicle in which he was a passenger. Law enforcement conducted the search as part of an investigation into the vehicle's owner for drug trafficking, using a search warrant and two tracking warrants to monitor the vehicle's location. Kelley moved to suppress the evidence obtained through the warrants, arguing that he had a reasonable expectation of privacy in the vehicle.The trial court (Penobscot County, A. Murray, J.) denied Kelley's motion to suppress on the grounds that he lacked standing to challenge the search. Kelley argued that the court should not have reached the question of his standing because the State had stipulated that he had a reasonable expectation of privacy in the vehicle. However, the court concluded that standing is a threshold issue that must be addressed, and Kelley did not have a reasonable expectation of privacy in the vehicle.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the State's stipulation regarding Kelley's standing was not binding on the court and that Kelley lacked a reasonable expectation of privacy in the vehicle. The court noted that Kelley did not own the vehicle, had never driven it, and had only stored personal items in it for a short period. Therefore, Kelley did not have standing to challenge the search warrants, and the judgment of conviction was affirmed. View "State of Maine v. Kelley" on Justia Law

Ramel L. Sheppard was convicted of domestic violence aggravated assault after a jury trial in which the victim did not testify. The conviction was based in part on the victim's hearsay statement to a police officer identifying Sheppard as her attacker. Sheppard appealed, arguing that the trial court erred in admitting the hearsay statement as an excited utterance and that its admission violated his rights under the Confrontation Clause of the U.S. Constitution.The trial court (Androscoggin County) admitted the victim's statement under the excited utterance exception to the hearsay rule, finding that the statement was made spontaneously and while the victim was still under the stress of the assault. The court also determined that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. The jury found Sheppard guilty on two counts, but the court later merged one count into the other and sentenced Sheppard to seven years' imprisonment, with all but forty months suspended, and three years of probation.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that the trial court did not abuse its discretion in admitting the victim's statement as an excited utterance, as the statement was made spontaneously and under the stress of the assault. The court also held that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. Therefore, the admission of the statement did not violate Sheppard's rights under the Confrontation Clause. View "State of Maine v. Sheppard" on Justia Law

Dylan Ketcham was convicted of the murder of Jordan Johnson, attempted murder, and elevated aggravated assault against Caleb Trudeau. The incident occurred on January 24, 2020, when Ketcham and Johnson exchanged hostile messages and agreed to meet. Trudeau accompanied Johnson, expecting a fistfight. Ketcham shot Johnson in the head and attacked Trudeau with a machete, causing severe injuries. Johnson died days later, and Trudeau survived but with lasting impairments.The State initially charged Ketcham with elevated aggravated assault and later with murder after Johnson's death. A mental examination deemed Ketcham competent for trial. A mistrial was declared in September 2022 due to prejudicial evidence. Before the new trial, the court limited the admission of certain text messages between Johnson and Trudeau. During the January 2023 trial, the court allowed some messages to be discussed but limited their use to showing the relationship and state of mind, not self-defense. The jury found Ketcham guilty on all counts.The Maine Supreme Judicial Court reviewed the case. Ketcham argued that the trial court erred in limiting the jury's consideration of the messages and in not ordering a competency evaluation during the trial. He also challenged his sentence as a misapplication of sentencing principles and an illegal de facto life sentence. The court found no abuse of discretion in the trial court's handling of the messages or in its decision not to order a competency evaluation. The court also upheld the sentences, finding them proportionate to the crimes committed and not constituting a de facto life sentence. The judgment and sentence were affirmed. View "State of Maine v. Ketcham" on Justia Law

Trevor I. DesRosiers was convicted by a jury in the Penobscot County Unified Criminal Docket on three counts of sexual abuse of a minor and three counts of furnishing liquor to a minor. DesRosiers appealed, arguing insufficient evidence to prove he and the victim were not married during the sexual acts and to establish the victim’s age for Counts 1-4. He also claimed prosecutorial errors in closing arguments deprived him of a fair trial.The trial court denied DesRosiers’s motion for judgment of acquittal, and the jury found him guilty on all counts. The court sentenced him to concurrent terms of forty-two months for sexual abuse and three months for furnishing liquor, with all but twenty months suspended. DesRosiers appealed the conviction.The Maine Supreme Judicial Court reviewed the case. The court found sufficient evidence to support the jury’s conclusion that DesRosiers and the victim were not married, based on the victim’s age, living situation, and the nature of their relationship. The court also found sufficient evidence to establish the victim’s age during the offenses, as she was fifteen throughout the relevant period.Regarding prosecutorial errors, the court determined that most of the prosecutor’s comments did not constitute error. However, the prosecutor’s comment on DesRosiers’s invocation of his Fourth Amendment right was deemed error but not obvious error. The court concluded that this isolated comment did not undermine the trial’s integrity or affect the verdict.The Maine Supreme Judicial Court affirmed the judgment of conviction. View "State of Maine v. Desrosiers" on Justia Law

In May 2021, Ronald A. Harding lived with his girlfriend, her three children, and their infant son. On May 31, 2021, Harding was holding the infant when the child became unresponsive and later died. Medical examinations revealed that the infant suffered from a fatal brain injury consistent with non-accidental trauma, specifically shaken impact syndrome. Harding was arrested on June 4, 2021, and charged with manslaughter. He was later indicted by a grand jury on one count of manslaughter.The trial took place over four days in early 2023. The State presented testimony from medical professionals and experts who treated the infant and performed the autopsy. The defense argued that the death could have been caused by COVID-19 or an earlier injury, presenting testimony from their own expert, Dr. Jane Turner. The jury found Harding guilty of manslaughter. Harding's motions for a judgment of acquittal and a judgment notwithstanding the verdict were denied by the trial court.The Maine Supreme Judicial Court reviewed the case. Harding argued that the evidence was insufficient to support the conviction and that the State committed prosecutorial error during its closing argument. The court held that the evidence was sufficient for a rational jury to find Harding guilty beyond a reasonable doubt. The court also found that Harding had waived his prosecutorial error argument by withdrawing his request for a curative instruction during the trial. Consequently, the court affirmed the judgment of conviction. View "State of Maine v. Harding" on Justia Law

In May 2021, Ronald A. Harding lived with his girlfriend, her three children, and their infant son. On May 31, 2021, Harding was holding the infant when the child became unresponsive and later died. Medical examinations revealed that the infant suffered from a fatal brain injury consistent with non-accidental trauma, specifically shaken impact syndrome. Harding was arrested on June 4, 2021, and charged with manslaughter. A grand jury indicted him on June 30, 2021. During the trial, the State presented evidence from medical professionals and experts who testified that the infant's injuries were caused by traumatic head injury while in Harding's care.The Penobscot County Unified Criminal Docket oversaw the initial trial. Harding moved for a judgment of acquittal after the State rested its case and renewed the motion after the close of evidence, but the trial court denied both motions. The jury found Harding guilty of manslaughter, and the court entered a judgment of conviction on September 19, 2023. Harding was sentenced to fifteen years, with all but eight and a half years suspended, and six years of probation. Harding appealed, arguing insufficient evidence and prosecutorial error during closing arguments.The Maine Supreme Judicial Court reviewed the case. The court held that sufficient evidence supported the manslaughter conviction, noting that the jury was entitled to resolve conflicting evidence and determine witness credibility. The court also found that Harding waived his prosecutorial error argument by withdrawing his request for a curative instruction and not moving for a mistrial. Consequently, the court affirmed the judgment of conviction. View "In re Children of Destiny H." on Justia Law