Justia Maine Supreme Court Opinion Summaries

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

The defendant, an adult male in his fifties, was accused of engaging in unlawful sexual contact with his twelve-year-old great-niece while she was staying overnight at his home in October 2020. The victim disclosed the incident to her mother about a year later after family members encouraged her to speak up due to concerns arising from accusations the defendant had made against the victim’s cousin. The matter was reported to law enforcement and later discussed in a forensic interview. The defendant was subsequently indicted and proceeded to a jury trial.During the trial in the Cumberland County Unified Criminal Docket, significant evidentiary disputes arose. The State sought to introduce testimony regarding a subsequent incident in which the defendant allegedly offered a sex toy to the victim and another individual, arguing its relevance to intent and the relationship between the parties. The defense objected, citing prejudice and late disclosure, and initially, the trial court excluded the evidence but left open the possibility of reconsideration. As the trial progressed and new lines of questioning emerged, the court ultimately allowed this evidence, finding no unfair prejudice. The defense also attempted to introduce evidence that the defendant had threatened the victim’s cousin, theorizing it would demonstrate a motive to fabricate the allegations. The court excluded this testimony, finding it irrelevant because there was no evidence the victim knew of the threats or that her family conspired to fabricate the allegations.The jury found the defendant guilty, and the court imposed a sentence of eight years, with a portion suspended and a probation period. On appeal, the Maine Supreme Judicial Court held that the trial court acted within its discretion in admitting the evidence of the subsequent sexual behavior and did not err in excluding the evidence of threats toward the cousin due to lack of relevance. The judgment of conviction was affirmed. View "State of Maine v. Cardona" on Justia Law

A father was charged with multiple offenses after his daughter reported that he had sexually assaulted her repeatedly over many years, with the earliest incident she could recall occurring when she was in second grade. The prosecution focused on three specific incidents of sexual assault that took place when the victim was sixteen, each on a different date and in different locations. The victim provided detailed testimony about these three incidents, and additional evidence included an audio recording made by the victim during one of the assaults. After the victim disclosed the abuse to her mother, law enforcement became involved, and a grand jury indicted the defendant on nine counts: three counts each of gross sexual assault, domestic violence assault, and endangering the welfare of a child, each set corresponding to one of the three incidents.The case proceeded to a jury trial in the Sagadahoc County Unified Criminal Docket. The jury initially reported a partial deadlock but, after receiving a standard instruction for deadlocked juries, returned guilty verdicts on all nine counts. At sentencing, the court grouped the charges by incident date, imposed concurrent sentences within each group, and ordered the groups to run consecutively, resulting in an aggregate sentence of twenty-seven years, with all but seventeen years suspended and three years of probation. The defendant appealed both his convictions and his sentence, arguing that the trial court erred by not giving a specific unanimity instruction to the jury and by double counting the multiplicity of assaults during sentencing.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that a specific unanimity instruction was not required because each count was tied to a distinct incident on a specific date, and the jury instructions sufficiently ensured unanimity. The Court also held that the sentencing court did not err by considering the number of assaults at different points in its analysis, as this was consistent with established sentencing practices and did not constitute impermissible double counting. View "State v. Chase" on Justia Law

Heather M. Hodgson was charged with several offenses following an incident at her home involving her husband and their two children. The dispute began after her husband purchased alcohol, which upset Hodgson. Both consumed alcohol, and an argument ensued. During the altercation, Hodgson pointed a loaded firearm at her husband and fired a “warning shot” at the floor near his feet. The couple’s three-year-old child was present in the home and had come out of the bedroom during the argument. Hodgson was subsequently indicted on multiple charges, including domestic violence reckless conduct with a dangerous weapon, domestic violence criminal threatening with a dangerous weapon, and endangering the welfare of a child.The case was tried without a jury in the Kennebec County Unified Criminal Docket. After the State presented its evidence, Hodgson moved for acquittal on some counts, which the court granted in part. Hodgson testified, claiming self-defense, but the court found her account not credible. The court found her guilty on three counts: domestic violence reckless conduct with a dangerous weapon, domestic violence criminal threatening with a dangerous weapon, and endangering the welfare of a child. At sentencing, the court declined to impose the mandatory minimum one-year sentence for the reckless conduct charge, instead sentencing Hodgson to three years with all but ninety days suspended and probation.On appeal, the Maine Supreme Judicial Court reviewed both Hodgson’s challenge to the sufficiency of the evidence and the State’s appeal regarding the sentence. The Court affirmed Hodgson’s convictions, finding the evidence sufficient. However, it held that the trial court erred by not imposing the mandatory minimum one-year sentence required by statute for domestic violence reckless conduct with a dangerous weapon. The Court vacated the sentence for that count and remanded for resentencing consistent with the statutory requirement. View "State v. Hodgson" on Justia Law