Justia Maine Supreme Court Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant’s conviction for operating under the influence (OUI), operating after habitual offender revocation, and driving to endanger, entered by the trial court after a jury trial. The court held (1) the trial court did not abuse its discretion in denying Defendant’s motion for a mistrial after an officer testified that Defendant was on probation at the time of his arrest; (2) the prosecutor did not commit misconduct; and (3) the trial court did not err by not instructing the jury on the competing harms justification as to the charges of operating under the influence and driving to endanger. View "State v. Nobles" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court denying the State’s motion to reconsider the court’s order dismissing, with prejudice, thirteen of the State’s fifteen counts against Defendant as a sanction for an alleged discovery violation. Although the trial court noted that the discovery violation was not the result of any bad faith or improper effort, it determined that dismissal was the appropriate sanction. The Supreme Judicial Court remanded the case to the trial court, holding that the court erred as a matter of law by concluding that the State committed a discovery violation, and therefore, it had no authority to sanction the State. View "State v. Hassan" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of hindering apprehension, obstructing government administration, and refusing to submit to arrest. On appeal, Defendant argued that the trial court’s jury instructions on the justification of defense of premises were deficient. The Supreme Judicial Court disagreed, holding (1) a citizen is not justified in using nondeadly force against a law enforcement officer for the purpose of defending one’s premises; and (2) because the Criminal Code does not create a justification that allowed Defendant to use nondeadly force against the law enforcement officer in this case in order to defend her premises, Defendant was not entitled to any instruction on that issue. View "State v. French" on Justia Law

Me. Rev. Stat. 17-A, 1112 is facially constitutional, and, in the instant case, the trial court’s admission of a lab certificate in lieu of live witness testimony pursuant to that statute was not a violation of Defendant’s right of confrontation.Defendant appealed from a judgment, entered after a jury trial, convicting her of unlawful trafficking of a schedule W drug. At issue was whether the trial court’s admission of a lab certificate identifying a substance exchanged in a controlled purchase as methamphetamine. The court admitted the lab certificate in lieu of the testimony of the chemist pursuant to section 1112. The Supreme Court affirmed, holding (1) section 1112 is facially constitutional; (2) Defendant’s failure to timely demand a live witness pursuant to section 1112 effected a voluntary, knowing, and intentional waiver of her Confrontation Clause rights; and (3) therefore, the trial court did not err in allowing into admission the chemist’s certificate in lieu of live testimony. View "State v. Jones" on Justia Law

The motion court did not err by applying the inevitable discovery doctrine to deny Defendant's motion to suppress evidence of drugs found on his person before the issuance of a search warrant.The Unified Criminal Docket found Defendant guilty of unlawful trafficking in scheduled drugs and ordering a criminal forfeiture. In denying Defendant’s motion to suppress drug evidence, the trial court found that law enforcement officers’ warrantless entry into an apartment was not justified by exigent circumstances but that it was highly likely that the officers inevitably would have discovered drugs. The Supreme Court affirmed the denial of the motion to suppress, holding (1) the motion court did not err by finding that the police inevitably would have discovered the drug evidence at issue by lawful means; and (2) application of the inevitable discovery doctrine does not create an incentive for police misconduct and does not significantly weaken Fourth Amendment protections. View "State v. Prinkleton" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of possession of sexually explicit material depicting a minor under twelve years old and the sentence imposed in connection with the conviction. The court imposed a sentence of three years’ incarceration and two years of probation with certain conditions, including a restriction against unsupervised contact with children under the age of sixteen years. Defendant appealed, challenging the denial of his motion to suppress his statements to the police and the condition of his probation permitting him only supervised contact with his infant son. The Supreme Court held (1) the admission of Defendant’s confession was fundamentally fair; and (2) the “no unsupervised contact” provision of Defendant’s probation was within the court’s authority and did not violate Defendant’s constitutional rights. View "State v. Annis" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant’s motion for a new trial, which Defendant brought pursuant to the post-conviction DNA analysis statute, Me. Rev. Stat. 15, 2135-2138. The Supreme Judicial Court held that the district court did not err or abuse its discretion by (1) finding that Defendant failed to show by clear and convincing evidence that new DNA evidence admitted at the hearing on Defendant’s motion made it probable that a different verdict would result upon a new trial; and (2) declining to consider evidence pointing to an alternative suspect upon finding that the proffered evidence was not relevant to the new DNA evidence. View "State v. Bates" on Justia Law

The evidence was insufficient to support the superior court’s revocation of Defendant’s probation.Defendant was sentenced to a term of years and probation after pleading guilty to gross sexual assault and unlawful sexual contact. Several years after Defendant served his sentence, the State filed a motion to revoke Defendant’s probation on the grounds that Defendant failed to report to his probation officer as required on two occasions and walked in front of a public school. The Supreme Judicial Court vacated the judgment of the superior court, holding that the State failed to meet its burden to prove, by a preponderance of the evidence, that Defendant was on probation at the time of his alleged probation violations. View "State v. Kibbe" on Justia Law