Justia Maine Supreme Court Opinion Summaries

A man was observed by a police officer in an area behind several businesses that was marked with no-trespassing signs and known for illicit drug activity. When the officer approached, the man acted suspiciously, attempted to walk away, and appeared to conceal something in his pocket. The officer, who recognized the man from previous encounters near drug houses, learned that the man was subject to bail conditions permitting searches based on articulable suspicion of drug use or possession. Upon searching him, the officer found fentanyl and cocaine, as well as drug paraphernalia and cash.The Superior Court (Penobscot County) denied the defendant’s motion to suppress the evidence, finding that the officer had reasonable suspicion to stop and search him. At trial, the court allowed expert testimony from a Maine Drug Enforcement Agency commander regarding drug prices, after offering the defense a continuance to address late disclosure, which the defense declined. The jury convicted the defendant of aggravated trafficking in fentanyl and unlawful trafficking in cocaine. The court declined to instruct the jury on unlawful possession as a lesser included offense for the fentanyl charge but did so for the cocaine charge. The defendant was sentenced to seven years (with four suspended) for aggravated trafficking, four years concurrent for cocaine trafficking, and thirty days for violating a condition of release, with forfeiture ordered.On appeal, the Maine Supreme Judicial Court affirmed the judgment. The Court held that the officer had reasonable suspicion for both the stop and the search, the trial court did not abuse its discretion in admitting the expert testimony or in its handling of the discovery issue, and any error in failing to instruct on a lesser included offense for the fentanyl charge was harmless. The Court also found no error in the sentencing analysis. View "State of Maine v. Schlosser" on Justia Law

Law enforcement stopped a vehicle driven by the defendant on December 1, 2021, and discovered drug paraphernalia, cash, and various illegal drugs in the car and on her person. The defendant admitted ownership of the drugs. On January 20, 2022, after she used a counterfeit bill to post bail for another individual, police searched her vehicle again and found large quantities of fentanyl, methamphetamine, and cocaine, as well as drug packaging materials and a firearm. The following day, a search of her home uncovered more drugs, cash, firearms, and evidence of drug sales. In total, authorities seized significant amounts of fentanyl, methamphetamine, and cocaine. The defendant was indicted on three counts of aggravated trafficking of scheduled drugs and one count of unlawful possession, with the State aggregating the drug quantities across the incidents as part of a continuing scheme.The case was tried before a jury in the Penobscot County Unified Criminal Docket. During closing arguments, defense counsel suggested that some of the drugs belonged to a passenger, referencing evidence that the passenger brought a Walmart bag containing drugs into the car. The State objected, claiming this was not in evidence, and the trial court sustained the objection. The jury found the defendant guilty on all counts, and the court entered judgment and ordered forfeiture of property. The defendant appealed, arguing that the court’s ruling during closing argument improperly commented on the evidence and infringed on her rights.The Maine Supreme Judicial Court held that the trial court erred in sustaining the State’s objection, as there was evidence supporting the defense’s argument. However, the Court concluded that the error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt, the opportunity for the defense to present its theory, and the court’s instructions to the jury. The judgment of conviction was affirmed. View "State of Maine v. Quirion" on Justia Law

Jason Servil was charged with murder and aggravated assault after he fatally stabbed his ex-girlfriend and attacked a man accompanying her with a crowbar. Following his indictment, Servil entered into a plea agreement with the State, capping his potential sentence for murder at forty-five years, though he was permitted to argue for a lesser term. He pleaded guilty to both charges, and the court scheduled a sentencing hearing, during which it heard statements from the victims’ family members, a mental health professional, Servil’s relatives, and Servil himself.The Somerset County Unified Criminal Docket accepted Servil’s guilty pleas and, after the sentencing hearing, imposed a forty-five-year sentence for murder and a concurrent ten-year sentence for aggravated assault, along with restitution. During sentencing, the court conducted the required two-step analysis for murder convictions, considering aggravating and mitigating factors. Notably, the court independently obtained and read the victim’s obituary into the record as part of its analysis of the subjective effect on the victim. Servil appealed, arguing that the court’s use of the obituary constituted an abuse of discretion and violated his rights. The Sentence Review Panel granted his application for leave to appeal.The Maine Supreme Judicial Court reviewed the case and determined that the sentencing court abused its discretion by relying on information from the victim’s obituary, which it had obtained independently and was not disclosed to the defense prior to sentencing. The Supreme Judicial Court held that this reliance on extrajudicial information was impermissible and that the error was not harmless. As a result, the Court vacated Servil’s sentences and remanded the case for resentencing before a different judge. View "State of Maine v. Servil" on Justia Law

The case concerns Neil T. MacLean, who was convicted by a jury of attempted murder and two counts of arson after he set fire to his bed in an apartment building where he and his wife lived, along with other residents. On the night of the incident, MacLean had been drinking and was aware that his wife was sleeping nearby. After the fire started, his wife called 9-1-1, and police officers evacuated her and eventually removed MacLean from the burning apartment. No fatalities occurred, but two officers suffered smoke inhalation. MacLean later admitted to an investigator that he intended to kill himself, his wife, and the other residents.Following the incident, MacLean was charged and underwent mental health evaluations. He pleaded not guilty, and after unsuccessful settlement discussions and further mental health examination, the case proceeded to a jury trial in the Somerset County Unified Criminal Docket. The jury found him guilty on all counts. The trial court sentenced him to twenty-five years, with all but fifteen years suspended, for attempted murder, and concurrent fifteen-year sentences for the arson convictions, plus probation. MacLean appealed, raising issues regarding jury instructions, evidentiary rulings, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court did not commit obvious error by failing to instruct the jury on the defense of abnormal condition of the mind, as the evidence did not warrant such an instruction. The court also found that any error in admitting testimony from MacLean’s wife was harmless, and that the trial court did not abuse its discretion in denying a mistrial or curative instruction after the prosecutor referred to the wife as a hostile witness. However, the court agreed with both parties that the convictions should have been merged for sentencing, so it vacated the sentence and remanded for resentencing, while affirming the judgment of conviction in all other respects. View "State of Maine v. MacLean" on Justia Law

The defendant was convicted after a bench trial of several offenses, including attempted murder, domestic violence aggravated assault, domestic violence criminal threatening, assault on an officer, and violating a condition of release. The convictions arose from an incident in which the defendant, following a period of repeated contact with his former partner, attacked her in a hotel parking lot. The attack involved strangulation, threats to kill, and physical violence, resulting in significant injuries to the victim. Bystanders, including a hotel clerk and a van driver, intervened, and police officers ultimately subdued and arrested the defendant after a struggle in which an officer was bitten and his firearm was nearly taken.The Kennebec County Unified Criminal Docket (Murphy, J.) found the defendant guilty of the charged offenses. At sentencing, the court imposed a thirty-year sentence for attempted murder, with all but eighteen years suspended and four years of probation, and additional sentences for the other convictions. In determining the sentence for attempted murder, the court considered the brutality and persistence of the attack as aggravating factors, as well as the defendant’s lack of criminal history and acceptance of responsibility as mitigating factors. The court declined to treat the defendant’s “blind jealous rage” as a mitigating factor, finding it was not a biologically based mental illness.On appeal, the Maine Supreme Judicial Court reviewed two arguments: that the trial court violated the Eighth Amendment by not considering the defendant’s “blind rage” as a mitigating factor, and that the court erred in finding as an aggravating factor that the defendant assaulted the hotel clerk. The Supreme Judicial Court held that the Eighth Amendment does not require a sentencing court in a noncapital case to consider unprovoked “blind rage” as a mitigating factor. However, the Court found plain error in the trial court’s reliance on an unsupported finding that the defendant assaulted the hotel clerk as an aggravating factor. The judgment of sentence for attempted murder was vacated and the case remanded for resentencing. View "State of Maine v. Goncalves" on Justia Law

Kyle M. Fitzgerald was stopped by Maine State Police on Interstate 295 for not wearing a seatbelt and driving significantly below the speed limit. During the stop, Fitzgerald and her passengers gave inconsistent and confusing answers about their destination and how long they had known each other. One passenger was particularly anxious, another was standoffish, and a third pretended to be asleep. The police officer, Trooper Young, requested a drug detection dog, which arrived seventy-seven minutes after the stop began. The dog indicated the presence of drugs, leading to a search that uncovered a substantial quantity of illegal drugs.The trial court (Cumberland County) granted Fitzgerald’s motion to suppress the evidence obtained from the search, finding that the officers lacked probable cause. The court determined that the reasonable suspicion justifying the initial stop had been resolved well before the dog arrived, and there was no reasonable suspicion of illegal drug activity to justify prolonging the detention.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the duration of Fitzgerald’s detention exceeded the constitutional limit once the officer confirmed the identity of one of the passengers, which was thirty-four minutes before the drug detection dog arrived. The court concluded that the officer’s suspicion of illegal drug activity was based on a general hunch rather than an articulable and objectively reasonable suspicion. Therefore, the prolonged detention violated the Fourth Amendment, and the evidence obtained from the search was rightly suppressed. View "State v. Fitzgerald" on Justia Law

Townsend Thorndike was convicted of unlawful sexual contact and visual sexual aggression against a child. The charges stemmed from alleged sexual abuse that occurred in the summer of 2021 when the victim was six years old. The State sought to admit a video recording of the victim’s forensic interview under a statutory hearsay exception. Thorndike argued that the statute allowing the video’s admission was unconstitutionally enacted as emergency legislation and violated the separation of powers clause in the Maine Constitution.The trial court initially granted the State’s motion to admit the video but later vacated its order, concluding the statute did not apply retroactively to pending cases. The State then sought and obtained an emergency legislative amendment clarifying the statute’s retroactive applicability. The trial court reinstated its original order, allowing the video’s admission. Thorndike was subsequently convicted on all counts, and the court sentenced him to fourteen years of imprisonment with all but eight years suspended, plus six years of probation.The Maine Supreme Judicial Court reviewed the case and upheld the trial court’s decision. The Court found that the emergency enactment of the statutory amendment was constitutionally valid, as the preamble expressed sufficient facts to constitute an emergency. The Court also determined that the legislative action did not violate the separation of powers doctrine, as it did not mandate the admission of evidence but clarified the statute’s applicability to pending cases. The Court affirmed Thorndike’s conviction and the trial court’s admission of the forensic interview video. View "State of Maine v. Thorndike" on Justia Law

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