Justia Maine Supreme Court Opinion Summaries

Steven Edwards was convicted by a jury of eighteen counts of possession of sexually explicit material involving minors under 12 years old. The charges stemmed from images found on his computer during a search executed with a warrant. Edwards challenged the court's decisions on several motions, including a motion to suppress evidence, arguing the warrant was based on stale information, and motions for judgment of acquittal, mistrial, and a new trial.The Somerset County court denied Edwards's motion to suppress, finding that the information supporting the warrant was not stale. The court noted that the Maine State Police Computer Crimes Unit had received multiple tips from the National Center for Missing and Exploited Children about uploads from Edwards's IP address. The court also found that consumers of child pornography often retain such material for long periods, supporting the warrant's issuance.At trial, the court heard testimony from law enforcement and forensic experts. Edwards moved for a judgment of acquittal, arguing insufficient evidence that he possessed or accessed the images with intent to view them. The court denied the motion, and the jury found Edwards guilty on all counts. Edwards's post-trial motions for a mistrial and a new trial were also denied, despite his argument that the prosecutor's comments during closing arguments were prejudicial.The Maine Supreme Judicial Court reviewed the case and affirmed the lower court's decisions. The court held that the information supporting the search warrant was not stale and that there was sufficient evidence for the jury to find Edwards guilty. The court also found that the trial court's curative instruction was adequate to address any potential prejudice from the prosecutor's comments, and there was no abuse of discretion in denying the motions for a mistrial and a new trial. View "State of Maine v. Edwards" on Justia Law

Michael T. Smith was convicted of twelve counts of unlawful sexual contact after a jury trial. The charges stemmed from allegations that Smith sexually abused his stepdaughter between 2011 and 2014 and his daughter between 2011 and 2019. The Oxford County Sheriff’s Office received a report in September 2019, leading to separate interviews of the victims. Smith’s stepdaughter disclosed abuse, resulting in an initial indictment. Later, Smith’s daughter also reported abuse, leading to a superseding indictment with additional charges.The trial court denied Smith’s motion for relief from prejudicial joinder, which sought to separate the charges involving his stepdaughter from those involving his daughter. The court found the charges were connected by time, purpose, and modus operandi, and that evidence of abuse of one victim would be admissible in a trial concerning the other. The court also allowed Kathy Harvey-Brown, a forensic interviewer with a background in social work, to testify as an expert on delayed disclosure of child sexual abuse, despite Smith’s objections regarding her qualifications.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decisions. The court held that the joinder of charges was proper and did not result in undue prejudice, as the evidence of abuse was interconnected and would be admissible in separate trials. The court also found that Harvey-Brown was qualified to testify based on her extensive training, experience, and familiarity with the relevant research. The court concluded that the trial court did not abuse its discretion in either denying the motion for relief from joinder or in allowing the expert testimony. View "State of Maine v. Smith" on Justia Law

Matthew A. Dennis was convicted of possession of a firearm by a prohibited person and violation of a condition of release following a jury-waived trial. The case arose when Officer Seth Burnes responded to a report of a disturbance at 68 Elm Street, where Dennis, who was under bail conditions to avoid contact with the victim, was found arguing with the victim. During the incident, Dennis was seen with a jacket containing a black-powder pistol, which appeared to have been fired. Dennis was arrested and charged accordingly.The trial court (Penobscot County, A. Murray, J.) denied Dennis's motion to suppress evidence and proceeded with a bench trial. During cross-examination, it was revealed that the pistol had been test-fired by police six days before the trial, and this information had been uploaded to the ShareFile platform used for discovery. Dennis's counsel argued that the late disclosure was unfair and requested dismissal or exclusion of the evidence. The court found no discovery violation but acknowledged the late disclosure and allowed Dennis to review the test-firing video and offered the opportunity to conduct his own test-firing, which Dennis declined.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that there was no discovery violation as the test result was provided within two days of its existence and before the trial. The court found that the trial court's remedy, which included allowing Dennis to review the test-firing video and offering the opportunity for his own test, was appropriate and did not deprive Dennis of a fair trial. The court concluded that the trial court's actions sufficiently mitigated any potential prejudicial effect of the late test-firing. View "State of Maine v. Dennis" on Justia Law

Pedro Rosario was convicted of aggravated trafficking of scheduled drugs in 2021 and sentenced to twenty-five years in prison, with ten years suspended, four years of probation, and a $25,000 fine. His conviction was affirmed by the Maine Supreme Judicial Court in 2022. In April 2023, Rosario filed a motion to vacate the judgment and for a new trial, alleging that a juror was improperly seated and biased. The State accepted the allegations as true for the purposes of the motion.The trial court held a non-testimonial hearing and found that during jury selection, Rosario’s counsel wanted to voir dire Juror 23, but another juror was brought forward by mistake. Juror 23 was selected as an alternate but was mistakenly seated as a juror when another juror was dismissed. Rosario’s attorney did not object at the time. Later, Rosario’s attorney discovered that Juror 23 had attended high school with the District Attorney but had not spoken to him since. The trial court determined that this information was not newly discovered evidence and denied Rosario’s motion for a new trial.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that Rosario’s motion was untimely under M.R.U. Crim. P. 33, as the information about Juror 23 was known before the trial concluded. The court also found no evidence of juror bias or misconduct that would warrant a new trial. The court concluded that Rosario received a fair trial by an impartial jury and upheld the trial court’s judgment. View "State of Maine v. Rosario" on Justia Law

In this case, the defendant was convicted of gross sexual assault and unlawful sexual contact involving an eleven-year-old victim who frequently visited the defendant's home. The defendant admitted to engaging in sexual acts with the victim during a police interview. The defendant was charged by criminal complaint and later by indictment, to which he pleaded not guilty.The trial court denied the defendant's motions to suppress his statements made during the police interview, determining that he was not in custody and that his statements were voluntary. The court found that the interview was non-custodial, conducted in a conversational manner, and that the defendant was informed he could leave at any time. The court also found no evidence that the defendant's hearing issues rendered his statements involuntary.During the trial, the jury heard testimony from the victim and the detective, and the court admitted the recorded interview and text messages between the defendant and the victim. The prosecutor made statements during closing arguments about the victim's credibility and the meaning of emojis in the text messages, which the defendant argued were improper. The court provided curative instructions to the jury regarding the prosecutor's statements.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The Court held that the trial court did not err in denying the motions to suppress, as the defendant was not in custody and his statements were voluntary. The Court also found that any prosecutorial errors during closing arguments were harmless and did not affect the defendant's substantial rights. The judgment of conviction was affirmed. View "State of Maine v. Farley" on Justia Law

Ernest B. Weidul was convicted of manslaughter and other charges in 2012. He later filed a petition for post-conviction relief, alleging that he had received ineffective assistance of counsel. The justice who presided at Weidul’s trial and during the first two days of the post-conviction hearing retired before the hearing was completed, and a different justice presided during the third day of hearing and rendered a judgment denying the petition. Weidul appealed, arguing that the judgment should be vacated because the justice who rendered it did not observe the testimony of the witnesses who testified during the first two days of the hearing and did not permit Weidul to recall those witnesses except for questioning on areas not covered previously.The lower courts had denied Weidul's petition for post-conviction relief. The justice who presided over the first two days of the post-conviction hearing retired before the hearing was completed, and a different justice presided over the third day of the hearing and rendered the judgment denying the petition. Weidul appealed this decision, arguing that the second justice should not have been able to make a judgment without observing the testimony of the witnesses who testified during the first two days of the hearing.The Maine Supreme Judicial Court agreed with Weidul, stating that there is no provision in the rules of procedure authorizing a justice who did not preside during disputed live testimony during a post-conviction hearing to adjudicate the credibility of the testimony over objection. The court found that the error was not harmless and vacated the judgment, remanding the case for additional proceedings. View "Weidul v. State" on Justia Law

The case involves Ricky Whitney, who was convicted for sexual exploitation of a minor. Whitney had sent messages to a minor, soliciting her to send explicit photographs. The minor, disturbed by the request, showed the messages to her mother, who then took over the conversation, pretending to be the minor. The mother sent a stock photo of a girl in shorts to Whitney, who then sent additional messages soliciting explicit photographs. The court found that the minor did not see these additional messages.The trial court in Penobscot County, Maine, found Whitney guilty of sexual exploitation of a minor and sentenced him to five years in prison. The court also revoked Whitney's probation in a separate matter and imposed the remaining five years of his suspended sentence, to run concurrently with the sentence for the conviction of sexual exploitation of a minor. Whitney appealed, arguing that the evidence was insufficient to support the conviction because the court did not find beyond a reasonable doubt that the minor received the solicitation to send explicit photographs.The Maine Supreme Judicial Court agreed with Whitney. The court found that the statute under which Whitney was convicted requires proof that the person being solicited is actually under the age of sixteen. The court stated that it is not sufficient that a defendant intended to solicit a minor; he must solicit a person who is in fact a minor. Because the trial court explicitly stated that it could not find beyond a reasonable doubt that the minor received the solicitation, an element of the offense was missing. Therefore, the court found there was insufficient evidence to find beyond a reasonable doubt that Whitney committed the crime of sexual exploitation of a minor. The court vacated the judgment of conviction and remanded the case for entry of a judgment of acquittal. View "State v. Whitney" on Justia Law

Corydon Judkins was convicted of domestic violence assault after a jury trial. The case revolved around an incident where the police were called to Judkins' apartment, and the victim alleged that Judkins had assaulted her. The victim's statements were recorded by the responding officer's body camera. However, the victim did not testify at the trial. The State introduced the body camera footage, including the victim's statements, as evidence. Judkins objected, arguing that his constitutional right to confront witnesses was violated as he could not cross-examine the victim. The trial court admitted the footage, citing the excited utterance exception to the hearsay rule.The Maine Supreme Judicial Court reviewed the case. The State conceded that the victim's statements were testimonial and should not have been admitted. The court agreed, stating that once Judkins was removed from the apartment, there was no ongoing emergency that would support the admission of the victim's answers as non-testimonial statements. The court found that the victim's testimonial statements were inadmissible as she did not testify at trial and Judkins had no prior opportunity to cross-examine her.The court then considered whether the error was harmless. It noted that the State relied heavily on the victim's statements in the video to prove its case, and the evidence of Judkins's guilt was not overwhelming. The court also noted that the jury had asked to review the body camera footage during its deliberations. The court concluded that it could not determine beyond a reasonable doubt that the victim's statements on the body camera recording did not affect the verdict. Therefore, the court vacated the judgment and remanded the case for further proceedings. View "State of Maine v. Judkins" on Justia Law

The defendant, James A. Green, was convicted of operating under the influence (OUI) after being found slumped over in his vehicle at a green traffic light. The arresting officer noticed signs of impairment, conducted field sobriety tests, and arrested Green. Another officer, trained as a Drug Recognition Expert (DRE), evaluated Green and found evidence of drug use. Green was charged and pleaded not guilty.Prior to the trial, Green filed a motion to limit the DRE's testimony, arguing that the DRE should not be qualified as an expert under Maine Rule of Evidence 702. He also claimed that the State violated discovery rules by not providing an additional expert witness report from the DRE. The trial court reserved ruling on the DRE's opinions and stated that it would address the issues during the trial if necessary. During the trial, the DRE testified extensively about his background, credentials, and experience, and gave his opinion as a DRE. Green did not object to the DRE's qualifications or opinions during the trial.The jury found Green guilty, and he appealed, arguing that the State violated discovery rules and that the DRE should have been qualified as an expert witness before offering his opinion. The Maine Supreme Judicial Court disagreed, affirming the conviction. The court found that the State had provided the DRE's report as part of automatic discovery, fulfilling its obligations under the Maine Rules of Unified Criminal Procedure 16. The court also found that the DRE's testimony went beyond lay opinion testimony and was informed by his training and certification as a drug recognition expert. However, since Green did not object to the DRE's qualifications or opinions during the trial, his objection was unpreserved and was reviewed for obvious error. The court found no error that deprived Green of a fair trial or resulted in a serious injustice. View "State v. Green" on Justia Law

The case involves Nicholas P. Lovejoy, who was convicted of intentional or knowing murder. Lovejoy appealed his conviction, arguing that the court erred in denying his motion to suppress evidence obtained from an allegedly unlawful traffic stop and a subsequent warrantless search of his home. He also contended that the court abused its discretion in considering his mental state and post-crime conduct in its sentencing analysis.Prior to Lovejoy's conviction, his case was heard in the trial court where he entered a conditional guilty plea. The court denied his motion to suppress evidence obtained from the traffic stop and the search of his home. Lovejoy was subsequently convicted and sentenced to forty-two years of incarceration.In the Maine Supreme Judicial Court, Lovejoy's appeal was reviewed. The court found that the traffic stop was supported by reasonable, articulable suspicion and that the warrantless search of his home was a reasonable response to what law enforcement knew at the time to be an exigent circumstance. The court also concluded that it did not abuse its discretion in sentencing Lovejoy. Therefore, the court affirmed the lower court's decision. View "State of Maine v. Lovejoy" on Justia Law