Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction for one count of intentional or knowing or depraved indifference murder following a jury trial. On appeal, Defendant argued that the trial court abused its discretion in denying his motion for a new trial on the grounds of prosecutorial misconduct and error in admitting evidence of prior bad acts. The Supreme Judicial Court held (1) the prosecutor’s remarks during opening statements did not deprive Defendant of a fair trial; and (2) the trial court did not clearly err or abuse its discretion in admitting evidence of Defendant’s prior assault of the victim. View "State v. Pillsbury" on Justia Law

The Supreme Judicial Court held that the trial court did not err in refusing to instruct the jury during Defendant’s criminal trial that the jury needed to find that Defendant had acted intentionally or knowingly in order to find him guilty of possessing a loaded firearm in a motor vehicle and unlawfully driving deer. The Court concluded (1) the firearm offense is a strict liability crime and, therefore, no mens rea instruction was necessary; and (2) the crime of driving deer is not a strict liability crime and contains a mens rea component, but because the trial court’s instructions adequately and correctly conveyed the elements of both crimes to the jury, the trial court did not err in refusing Defendant’s jury instruction request. View "State v. Siracusa" on Justia Law

The Supreme Judicial Court held that the trial court did not err in excluding one of Defendant’s statements from a recorded interview with police that was admitted at Defendant’s jury trial, holding that the court’s exclusion of the statement that the victim “likes it rough” was not prejudicial to Defendant’s defense and did not violate his right to due process. In addition, the Court was unpersuaded by Defendant’s contention that the statement was admissible pursuant to Me. R. Crim. P. 412(b). The Court thus affirmed Defendant’s judgment of conviction for gross sexual assault, assault, domestic violence criminal threatening, and criminal restraint. View "State v. Grindle" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for operating under the influence, holding that the trial court did not err in concluding that Defendant’s defense that his operation of a motor vehicle was involuntary did not apply to the facts of this case. Specifically, the Court held (1) the trial court erred in concluding that the involuntariness defense can never apply to strict liability crimes; but (2) the court did not err to the extent that it concluded that the defense of voluntariness did not apply to the facts of the matter before it. During trial, Defendant argued that his conduct was directed by “command hallucinations,” and therefore, the involuntary conduct defense applied in this case. View "State v. Griffin" on Justia Law

Defendant appealed his conviction of operating under the influence (OUI) with a refusal to submit to a chemical test and of operating after suspension (OAS), arguing (1) the State failed to lay a proper foundation for the admission of testimony regarding horizontal gaze nystagmus (HGN) tests performed on Defendant after he was stopped for a traffic violation; and (2) the court committed obvious error by considering testimony from the OUI portion of the trial - as presented to the jury - to conclude that the State proved the operation element of the OAS charge - which was decided by the court. The Supreme Judicial Court affirmed, holding (1) the State laid a proper foundation for the admission of testimony regarding the HGN tests pursuant to State v. Taylor; and (2) where the trial court did not formally sever the OAS and OUI charges and, rather, the parties agreed before trial to have the court decide the OAS charge for “strategic reasons,” the court did not commit obvious error when it considered testimony presented to the jury on the OUI charge in deciding the OAS charge. View "State v. Hinkel" on Justia Law

Defendant was convicted of domestic violence assault, domestic violence stalking, and endangering the welfare of a child. The Supreme Judicial Court vacated the judgment of conviction as to the charge of domestic violence assault and remanded for entry of a judgment of acquittal on that charge, holding that the record contained insufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant’s conduct forming that basis for domestic violence assault occurred within the relevant limitations period. The Court also remanded to determine whether resentencing was necessary as to the stalking and endangering the welfare of a child charges. View "State v. Lacourse" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated assault, two counts of domestic violence assault, and related offenses. Defendant appealed, arguing, inter alia, that the court erred in denying his motion to suppress statements he made to a police officer prior to his arrest. Defendant also appealed his sentence. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that Defendant was not in custody for Miranda purposes and consequently denying his motion to suppress; (2) the court did not abuse its discretion in admitting the testimony of an expert witness who testified about the causes, effects, and symptoms of strangulation; and (3) the court did not abuse its discretion in sentencing Defendant. View "State v. Perry" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder. The Supreme Judicial Court affirmed the judgment, holding (1) the motion court did not err in denying Defendant’s motion to suppress statements he made to law enforcement officers prior to 12:44 p.m. on July 18, 2013 because Defendant was not in custody for Miranda purposes that morning; (2) the motion court did not err in concluding that the Miranda violation occurring after 12:44 p.m. on July 18 did not mandate suppression of statements made on July 23 and 24; (3) the State’s attorney did not commit prosecutorial misconduct during opening statement and closing argument; and (4) the State presented sufficient evidence to support the murder conviction. View "State v. Cote" on Justia Law

After a jury trial, Defendant was found guilty of domestic violence assault and obstructing the report of a crime or injury. The court sentenced Defendant to three years’ incarceration with all but nine months suspended and three years’ probation, plus fees. The Supreme Judicial Court affirmed, holding (1) the trial court did not commit prejudicial error by not sua sponte declaring a mistrial when the prosecutor commented on Defendant’s right not to testify during the State’s rebuttal closing argument; and (2) the trial court did not err by denying Defendant’s motions for a mistrial after the jury heard statements by the victim regarding Defendant’s prior interactions with police and the victim’s consultation with a domestic violence program and acquisition of a protection order. View "State v. Tarbox" on Justia Law

After a jury trial, Defendant was convicted of one count of murder and one count of arson. The jury also found Defendant’s co-defendant guilty of three counts of murder and one count of arson. The Supreme Judicial Court affirmed, holding that the trial court (1) did not err when it instructed the jury on the defense of duress for the arson charge only and not for the murder counts; (2) did not abuse its discretion in denying Defendant’s motion for relief from prejudicial joinder with his co-defendant; (3) did not abuse its discretion when it permitted a witness to testify about guns she observed in a motel room during a meeting with Defendant and his co-defendant; (4) did not err when it denied Defendant’s motion to suppress cell phone records used to locate Defendant; and (5) did not err when it allowed testimony that insinuated Defendant “harmed people over drug debts.” View "State v. Sexton" on Justia Law