Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of aggravated assault, domestic violence criminal threatening, and other offenses, holding that there was no error, obvious or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in admitting expert testimony regarding strangulation; (2) the trial court did not abuse its discretion in imposing consecutive sentences; and (3) the trial court did not err by considering Defendant's criminal history as an aggravating factor at sentencing. View "State v. Treadway" on Justia Law

The Supreme Judicial Court vacated the judgment of conviction for assault and violation of condition of release entered by the trial court after a jury trial, holding that the court erred in instructing the jury concerning the justification of defense of property set forth in Me. Rev. Stat. 17-A, 105.After a second trial, a jury found Defendant guilty of violating a condition of release. Defendant appealed, arguing that the trial court erred in instructing the jury concerning the justification of defense of property. The Supreme Court agreed and remanded the matter for a new trial, holding (1) the trial court's oral and written instructions concerning the statutory justification of defense of property was erroneous in more than one respect; and (2) the errors were highly prejudicial and constituted obvious error. View "State v. Lee" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for trafficking in prison contraband, unlawful possession of a scheduled drug, and violating a condition of release, holding that the trial court erred in its handling of the void dire process and in admitting certain evidence.On appeal, Defendant argued that the trial court abused its discretion when it denied his race-related voir dire questions and erred in partially denying his motion to suppress statements he made to a corrections officer upon his arrival to jail after his arrest. The Supreme Judicial Court agreed, holding (1) the voir dire process was not sufficient to disclose facts that would reveal juror bias; and (2) the trial court erred in denying Defendant's motion to suppress, and the error was not harmless. View "State v. Fleming" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant for failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999), Me. Rev. Stat. 34-A, 11227(2), holding that, due to inadequate representation by Defendant's trial counsel, the court committed obvious error by not addressing the constitutionality of SORNA of 1999, as retroactively applied to Defendant.In 1990, Defendant was convicted of four counts of unlawful sexual contact, and in 1992, he was convicted of gross sexual assault. Neither offense required Defendant to register as a sex offender. After the Legislature enacted SORNA of 1999, Defendant 's two convictions became subject to SORNA of 1999. In 2018, Defendant was found guilty of failure to comply with a duty under SORNA of 1999. On appeal, Defendant argued that the retroactive application of SORNA of 1999 to require him to register for life violated the state and federal constitutional prohibitions against ex post facto laws. The Supreme Judicial Court agreed, holding that it could not be said beyond a reasonable doubt that the retroactive application of SORNA of 1999 to Defendant's 1990 and 1992 convictions did not affect his substantial rights by virtue of a punitive alteration of his original sentences. View "State v. Proctor" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs, holding that the the trial court did not commit obvious error in instructing the jury and did not abuse its discretion by denying Defendant's motion for a new trial.Specifically, the Supreme Judicial Court held (1) the trial court did not err in instructing the jury on accomplice liability; (2) the jury instruction on a written report not admitted into evidence was not erroneous; and (3) the court did not abuse its discretion by denying Defendant's motion for a new trial on the basis that statements made during the State's closing argument impermissibly commented upon Defendant's out-of-state residence as evidence of his guilt. View "State v. Plummer" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of murder, holding that the trial court did not abuse its discretion by denying Defendant's motion for a new trial based on newly discovered evidence.Defendant's motion for a new trial was based on a statement allegedly made by his brother in the presence of another individual in which Defendant's brother claimed responsibility for the victim's murder. The trial court denied the motion. The Supreme Judicial Court affirmed, holding that the court did not abuse its discretion in determining that the brother's statement would not be admissible in a new trial and that, even if it were admissible, Defendant failed to establish that the proffered evidence would probably change the result if a new trial were granted. View "State v. Peaslee" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction for violating a condition of release, holding that the trial court lacked subject matter jurisdiction over Defendant's prosecution because the violation occurred in New Hampshire.Defendant was indicted for violating a condition of release. Defendant challenged the court's subject matter jurisdiction on the grounds that his alleged violation occurred outside Maine. The trial court determined that it had jurisdiction and found Defendant guilty. The Supreme Judicial Court vacated the judgment, holding that Maine lacked jurisdiction to prosecute Defendant on a charge of violating a condition of release for his conduct in New Hampshire. View "State v. Sloboda" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing or depraved indifference murder and gross sexual assault, holding that there was no error in the proceedings below.Specifically, the Court held (1) the trial court did not err by failing, sua sponte, to transfer venue based on the pretrial publicity about the case; (2) there was sufficient competent evidence on which a jury could reasonably find, beyond a reasonable doubt, that Defendant committed each element of both crimes; and (3) the trial court did not misapply any legal principles or abuse its discretion in imposing Defendant's sentence as to either crime. View "State v. Keene" on Justia Law

The Supreme Judicial Court vacated the trial court's judgment on remand after Defendant successfully argued that his two convictions of felony murder and robbery violated his right to be free from double jeopardy, holding that the trial court erred by allowing the State to dismiss the robbery count on remand rather than merging it into the felony murder count.On remand, instead of the trial court merging the counts, the robbery count was dismissed by the State. The Supreme Judicial Court vacated the judgment, holding (1) when a trial results in multiple verdicts for the same offense, the appropriate procedure to prevent a double jeopardy violation is to merge, not dismiss, the duplicative counts; and (2) the trial court's failure to hold a new sentencing hearing on remand and conduct a new sentencing analysis pursuant to Me. Rev. Stat. 17-A, 1602 deprived Defendant of a substantial right. View "State v. Armstrong" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of manslaughter, holding that the trial court did not err in denying Defendant's motions for a judgment of acquittal and for a new trial.On appeal, Defendant argued that the trial court erred by denying his motion for judgment of acquittal and by denying his motion for a new trial based on allegedly improper arguments proffered by the State during its closing argument. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support the conviction; and (2) Defendant did not demonstrate that the trial court erred by allowing the State to refer to Defendant's disability in its closing argument. View "State v. Bilodeau" on Justia Law