Justia Maine Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed the judgment of conviction entered in the trial court after a jury found Defendant guilty of intentional or knowing or depraved indifference murder and hindering apprehension or prosecution. The court held (1) the trial court did not err when it denied Defendant’s motion to suppress evidence of incriminating statements he made during a police interview and photographs of injuries to his body; and (2) the trial court did not err in denying Defendant’s motion for a new trial based on the State’s presentation of allegedly perjured testimony during Defendant’s trial. View "State v. McNaughton" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of conviction entered in the trial court after a jury found Defendant guilty of intentional or knowing or depraved indifference murder and hindering apprehension or prosecution. The court held (1) the trial court did not err when it denied Defendant’s motion to suppress evidence of incriminating statements he made during a police interview and photographs of injuries to his body; and (2) the trial court did not err in denying Defendant’s motion for a new trial based on the State’s presentation of allegedly perjured testimony during Defendant’s trial. View "State v. McNaughton" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the trial court after a jury found Defendant guilty of two counts of aggravated assault and two counts of aggravated driving to endanger. On appeal, Defendant argued that the trial court erred in admitting evidence of the victims’ injuries when she was willing to stipulate that they had sustained serious bodily injuries and in denying her motion for a new trial based on alleged prosecutorial misconduct. The Supreme Judicial Court held (1) the trial court did not err in its treatment of the evidence of the victims’ injuries; and (2) a comment by the prosecutor during closing arguments did not result in obvious error, and therefore, the trial court did not abuse its discretion in denying Defendant’s motion for a new trial. View "State v. Michaud" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the trial court after a jury found Defendant guilty of two counts of aggravated assault and two counts of aggravated driving to endanger. On appeal, Defendant argued that the trial court erred in admitting evidence of the victims’ injuries when she was willing to stipulate that they had sustained serious bodily injuries and in denying her motion for a new trial based on alleged prosecutorial misconduct. The Supreme Judicial Court held (1) the trial court did not err in its treatment of the evidence of the victims’ injuries; and (2) a comment by the prosecutor during closing arguments did not result in obvious error, and therefore, the trial court did not abuse its discretion in denying Defendant’s motion for a new trial. View "State v. Michaud" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment entered in the trial court convicting Defendant of several charges, including crimes of violence. After a jury-waived trial, Defendant was convicted of multiple charges arising from an incident where Defendant engaged in conduct while affected by a distorted view of reality. On appeal, Defendant argued that the trial court erred in interpreting Me. Rev. Stat. 17-A, 38 as applied to the evidence of Defendant’s mental condition and that the evidence of his mental abnormality foreclosed any determination that he acted with the required culpable state of mind. The Supreme Judicial Court held (1) the court’s application of section 38 was not in error, and (2) the evidence presented at trial supported the court’s factual findings beyond a reasonable doubt. View "State v. Proia" on Justia Law

Posted in: Criminal Law
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Defendant was twice convicted of cruelty to animals and ordered never to possess animals again. However, when Defendant was released from the prison sentence imposed after her second conviction, Defendant acquired a variety of animals. A jury rendered a verdict finding Defendant in contempt of court, and the trial court entered a judgment on the contempt verdict. Defendant was sentenced to 364 days in jail. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support the contempt finding; and (2) Defendant’s challenges to the contempt finding were without merit. View "State v. Murphy" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the postconviction court denying Defendant’s petition for postconviction review seeking relief from a judgment convicting Defendant of theft by misapplication of property and securities fraud. In his petition for postconviction review Defendant alleged ineffective assistance of trial counsel during plea negotiations and at trial, resulting in prejudice. In its judgment, the court found that Defendant’s arguments did not warrant relief. The Supreme Judicial Court affirmed, holding that the postconviction court was not compelled to find that Defendant established deficient representation or prejudice during either plea negotiations or trial. View "Philbrook v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant’s sentences totaling sixty years following Defendant’s guilty plea to four counts of gross sexual assault. This was Defendant’s second appeal arising out of the events that led to these charges. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court was not required to find specific aggravating circumstances before imposing what Defendant claimed was a de facto life sentence; and (2) the trial court did not impose an illegal sentence because Defendant's aggregate sentence was neither disproportionate to the offenses charged, nor did the sentence offend prevailing notions of decency. View "State v. Hoover" on Justia Law

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In 1970, Beauchene was acquitted of a murder charge by reason of mental disease or defect and was committed to the custody of the Department of Health and Human Services, where he remains committed pursuant to 15 M.R.S. 103. In 2016, Beauchene filed a petition seeking a discharge or a modified treatment plan. The court held a hearing at which three mental health professionals testified. The court denied the petition, finding that Beauchene had been diagnosed with “explosive personality,” had escaped from custody in 1973 and was returned to custody in 1978, had escaped again and fled to New York, where he was convicted of rape, sodomy, and assault in 1980, and has mental health symptoms consistent with anti-social personality disorder. The court concluded that Beauchene’s mental condition has “changed very little, if any[,] since” 1970, and if discharged, released, or placed in a modified treatment plan, Beauchene would pose a risk of harm or danger to himself or to others. The Maine Supreme Judicial Court affirmed, finding that Beauchene’s mental health symptoms constituted a “mental disease or defect” and that the statute provides sufficient notice and is not unconstitutionally vague and rejecting a due process claim. View "Beauchene v. State of Maine" on Justia Law

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The Supreme Judicial Court affirmed Defendant’s convictions, entered after a jury trial, for one count of theft by unauthorized taking or transfer, eleven counts of failure to pay tax or file a Maine State tax return, and one count of tampering with public records or information. On appeal, Defendant argued that there was insufficient evidence for the jury to find her guilty of theft and tampering with public records. The Supreme Judicial Court held (1) there was sufficient evidence for the jury to find each element of theft by unauthorized taking beyond a reasonable doubt; and (2) there was sufficient evidence to convict Defendant of tampering with public records. View "State v. Viles" on Justia Law

Posted in: Criminal Law