Articles Posted in Criminal Law

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The Supreme Judicial Court affirmed the judgment of conviction of manslaughter entered in the trial court, following a jury trial, holding that Defendant’s contentions of error were unavailing. Specifically, the Court held (1) the trial court did not err in denying Defendant’s motion to suppress statements she made to law enforcement officers during five different interviews; (2) the trial court did not err in instructing the jury on concurrent causation; and (3) the evidence was sufficient to support the jury’s conclusion, beyond a reasonable doubt, that Defendant caused the death of her infant son. View "State v. Hopkins" on Justia Law

Posted in: Criminal Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated trafficking in schedule W drugs, in violation of Me. Rev. Stat. 17-A, 1105-A(1)(D), holding that section 1105-A(1)(D) does not require the State to prove the weight of “pure” cocaine base. On appeal, Defendant argued that the statute required the State to prove the weight of pure cocaine base in isolation and that the trial court erred in failing to include that requirement in its instructions to the jury. The Supreme Judicial Court disagreed, holding (1) section 1105-A(1)(D) does not require the State to prove the weight of “pure” cocaine base; and (2) the court did not err when it instructed the jury that “[c]ocaine base includes any mixture or preparation that contains any quantity of cocaine base, which is the alkaloid base of cocaine.” View "State v. McLaughlin" on Justia Law

Posted in: Criminal Law

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The Supreme Judicial Court held that the trial court did not err in determining that the State did not engage in purposeful discrimination when it used a peremptory challenge that excluded from the jury the sole person of color in the jury pool. The Supreme Judicial Court affirmed the judgment of conviction entered in the Unified Criminal Docket convicting Defendant of reckless conduct with a dangerous weapon and criminal threatening with a dangerous weapon. On appeal, Defendant, who described himself as an African American male, argued that the State engaged in purposeful discrimination when it peremptorily challenged the juror at issue. The Supreme Judicial Court disagreed, holding that the trial court did not err when it determined that the prosecutor did not engage in purposeful discrimination. View "State v. Hollis" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court granting Appellant’s petition for postconviction relief and vacating his conviction of sexual abuse of a minor, holding that the court’s factual findings were supported by competent evidence in the record. After a hearing, the postconviction court found that Appellant had been deprived of the effective assistance of counsel and vacated his conviction. The Supreme Court affirmed, holding that the postconviction court’s finding that Appellant had been deprived of the effective assistance of counsel at trial was supported by competent record evidence. View "Fahnley v. State" on Justia Law

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The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress his blood-alcohol test results as having been procured without a warrant and without voluntary consent, holding that Defendant consented to the blood test. The blood test was taken upon probable cause to believe that the ability of Defendant, the driver of the motor vehicle, to operate the vehicle was impaired by intoxicants. On appeal, Defendant argued that the blood test was unconstitutional because it was taken without a warrant and her consent to the test was rendered involuntary by the warning of an increased minimum sentence if she refused to consent and was then convicted. The Supreme Judicial Court disagreed, holding that no coercion results from a law enforcement officer’s statement to a driver that, if she is ultimately convicted of operating under the influence, her failure to submit to a blood draw would subject her to an enhanced criminal penalty, including a minimum mandatory jail term. View "State v. Lemeunier-Fitzgerald" on Justia Law

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The Supreme Court dismissed the appeal brought by Sharon Carrillo from an order of the trial court denying her motion to disqualify the State’s attorneys from further participation in her prosecution for murder, holding that the appeal was interlocutory. Carrillo moved to disqualify the State’s attorneys for participating further in her prosecution, arguing that the prosecutors committed ethical violations by obtaining certain subpoenaed information. The trial court denied the motion to disqualify, determining that the prosecutors’ error did not warrant the extraordinary remedy of disqualification. Carrido appealed. The Supreme Court dismissed the appeal as interlocutory, holding the Carrillo did not meet her burden of demonstrating that the exception to the final judgment rule applied. View "State v. Carrillo" on Justia Law

Posted in: Criminal Law

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The Supreme Court held that a bail condition order prohibiting Defendant from possessing a “dangerous weapon” issued by a New Hampshire bail commissioner was a “similar order issued by a court…of another state” pursuant to Me. Rev. Stat. 19-A 4011(1)(A), and therefore, the State could prosecute Defendant for an alleged violation of that order. Defendant filed a motion to dismiss charges against him for violating a protective order. The trial court granted the motion to dismiss, concluding that any alleged violation in Maine of the New Hampshire conditions order could not subject Defendant to prosecution because the order failed to meet the definition of a “similar order” of protection “issued by a court…of another state” pursuant to section 4011(a)(A). The Supreme vacated the judgment and remanded the case to the trial court, holding that the New Hampshire order was a “similar order” under the statute. View "State v. Blum" on Justia Law

Posted in: Criminal Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of assault, holding that Defendant was not denied a fair trial because one of the jurors reported that she had felt pressured to return a guilty verdict. After the court informed the parties of the juror’s statement and invited the parties to be heard, the court concluded that there was no evidence of juror misconduct and that the guilty verdict would stand. The Supreme Judicial Court held that Defendant was not deprived of a fair trial because there was no evidence of outside influence, bias, or misconduct, and therefore, the juror’s statement that she felt pressured to return a guilty verdict fell within the categories of evidence prohibited from use by Me. R. Evid. 606(b)(1). View "State v. Leon" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of aggravated assault. Defendant, a mixed martial arts fighter, repeatedly punched the victim in the head, rendering the victim unconscious. A jury found him guilty of aggravated assault. On appeal, Defendant argued that there was insufficient evidence to support his conviction and that there was insufficient evidence supporting a finding that the State disproved self-defense. The Supreme Court disagreed, holding that the State presented sufficient evidence to prove that Defendant manifested an extreme indifference to the value of human life and to disprove Defendant’s self-defense justification beyond a reasonable doubt. View "State v. Matthews" on Justia Law

Posted in: Criminal Law

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The Supreme Judicial Court dismissed the appeal brought by Appellant challenging his sentence requiring him to pay $7,500 in restitution based on his involvement in damaging rental property from which he was evicted. The appeal was dismissed because Appellant did not properly assert that there was any illegality apparent on the record. Rather, Appellant challenged only the factual and discretionary determinations of the lower court. Because these are decisions that the Supreme Judicial Court does not review in a direct appeal of a sentence, the Court dismissed Appellant's appeal. View "State v. Plante" on Justia Law

Posted in: Criminal Law