Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court dismissed Appellant’s appeal from a judgment of conviction of manslaughter following Appellant’s unconditional open guilty plea, holding that Appellant provided no persuasive reason for the Court to depart from its longstanding jurisprudence strictly limiting direct appeal following a guilty plea.On appeal, Appellant argued that his plea was involuntary because he was coerced to accept the truth of all the facts recited by the State at the plea hearing and that he should not be required to show cause as to why his appeal should not be dismissed pursuant to State v. Huntley, 676 A.2d 501 (Me. 1996), and its progeny, which provide that a defendant may not appeal from a conviction entered upon his guilty plea except under certain circumstances. Because Appellant did not move to withdraw his unconditional plea before the court imposed the sentence and did not assert that the trial court lacked jurisdiction or that it imposed an excessive, cruel, or unusual sentence, this appeal must be dismissed. View "State v. Adams" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the sentencing court following Defendant’s guilty plea to an information charging him with felony murder. The sentencing court imposed a prison sentence of twenty years, all but ten years suspended, with four years’ probation and a restitution order. On appeal, Defendant argued that his sentence was unconstitutionally disproportionate and denied his constitutional right to equal protection. The Supreme Judicial Court disagreed, holding (1) Defendant’s offense and sentence did not generate an “inference of gross disproportionality”; and (2) notwithstanding the fact that Defendant’s codefendant received only a seven-year sentence, Defendant’s sentence did not violate Defendant’s equal protection rights. View "State v. Lopez" on Justia Law

The Supreme Judicial Court affirmed Defendant’s sentence entered in the Unified Criminal Docket following Defendant’s guilty plea to two counts of aggravated criminal operating under the influence and possession of a firearm by a prohibited person.On appeal, Defendant argued that, notwithstanding an agreement with the State that his sentence would not exceed an agreed upon “cap,” the sentencing court was required to explain its selection of the basic, maximum, and final periods of incarceration. In affirming, the Supreme Judicial Court held that any error in the court’s articulation of the sentence was not sufficiently prejudicial to affect the outcome of the proceeding and did not affect Defendant’s substantial rights. View "State v. Bean" on Justia Law

The Supreme Judicial Court vacated the order of the trial court quashing Appellant’s subpoenas of mental health records of the alleged victim without first viewing the records in camera and remanded for the production and in camera review of some or all of the requested mental health records.Appellant was convicted of gross sexual assault of a person under the age of fourteen and unlawful sexual contact. On appeal, Appellant challenged the court’s decision to quash his subpoenas of the mental health records, the court’s denial of his motion to suppress statements made to law enforcement, and the court’s denial of his motion for a judgment of acquittal. The Supreme Court held (1) the trial court did not err in its rulings on either Appellant’s motion to suppress or his motion for a judgment of acquittal; but (2) because it was relatively certain that the records contained some evidence concerning the exact crimes charged, and the identity of the alleged perpetrator was directly at issue at trial, due process demanded that the court must proceed with an in camera review. View "State v. Olah" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder. The Court held (1) the trial court did not abuse its discretion or commit obvious error when it excluded evidence that the State of Maine’s Chief Medical Examiner had been removed from his former position as Chief Medical Examiner for the Commonwealth of Massachusetts; and (2) the trial court did not err, much less commit obvious error, when it instructed the jury on how it could evaluate evidence of flight to avoid prosecution. View "State v. Haji-Hassan" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for three counts of murder and one count of gross sexual assault and the sentences of life imprisonment imposed on each of the murder counts. The Court held (1) the trial court abused its discretion by foreclosing Defendant’s cross-examination of the State’s Chief Medical Examiner concerning his termination from his position as the Chief Medical Examiner in Massachusetts, but the error was harmless; (2) the trial court did not clearly err by finding that the State had sufficiently established the chain of custody of the sexual assault kit used during the autopsy of one of the victims; (3) there was sufficient evidence to support the jury’s guilty verdict on the gross sexual assault charge; (4) the State did not commit prosecutorial misconduct in its opening statement; and (5) the trial court applied a correct standard of proof and did not abuse its discretion in determining the facts considered at sentencing. View "State v. Coleman" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of arson. On appeal, Defendant argued that the trial court violated his right to be protected against double jeopardy by admitting in his trial evidence on which the State relied to try to prove some of the charges of which Defendant was acquitted in a prior trial. The Supreme Judicial Court agreed, holding that the admission of that evidence was barred by collateral estoppel and violated Defendant’s right to be protected from double jeopardy and that the error was not harmless. View "State v. Weckerly" on Justia Law

The Supreme Judicial Court affirmed the trial court’s judgment convicting Defendant of three counts of possession of sexually explicit material, thus denying Defendant’s challenges to the denial of his motion to suppress statements and digital evidence obtained by the police after they entered his home. On appeal, Defendant argued that the trial court erred in finding that he consented to the police officers’ entry into his home, which resulted in the search and seizure of his computer. The Supreme Judicial Court held that there was sufficient evidence in the record to support a finding that Defendant consented to the officers’ entry. View "State v. Marquis" on Justia Law

In this criminal case, the Supreme Court dismissed Defendant’s appeal from the dismissal of his motion to vacate as moot and remanded the case for further proceedings.While Defendant’s competency to stand trial was under consideration and his motion to dismiss the charges on the basis of prosecutorial misconduct was pending, the trial court held an ex parte conference with the prosecutor to discuss the alleged prosecutorial misconduct. Defense counsel was not notified of the conference and did not consent to the ex parte communication. The same jurist later found Defendant competent to stand trial, denied Defendant's motion to dismiss, and denied Defendant’s motions to suppress. Defendant then entered a conditional guilty plea. While Defendant’s appeal remained pending, the Supreme Court authorized additional proceedings in the trial court so Defendant could obtain the transcript of the ex parte conference. Defendant then filed a motion to vacate the judgment of conviction and motion for the jurist’s recusal. The jurist recused himself. The court then dismissed Defendant’s motion to vacate. On appeal, the Supreme Court vacated all adjudicatory action undertaken after the ex parte conference and dismissed Defendant’s appeal form the dismissal of the motion to vacate as moot. View "State v. Bard" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated trafficking in scheduled drugs, unlawful possession of a scheduled drug, and unlawful possession of oxycodone. On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence that was found in the curtilage of his home and abused its discretion in denying his motion to exclude other evidence on the basis of a discovery violation. The Supreme Court disagreed, holding (1) the evidence obtained as a result of law enforcement officers’ search of bags they discovered within Defendant’s “curtilage” was properly admitted under the plain view exception and the inevitable discovery exception to the warrant requirement; and (2) the court did not err in denying Defendant’s motion to exclude the testimony of a pharmacist because the State had only recently notified Defendant that the pharmacist would testify in the place of another pharmacist who had also been on the witness list. View "State v. Sullivan" on Justia Law