Justia Maine Supreme Court Opinion Summaries

After a jury-waived trial, Defendant was convicted of manslaughter. The court sentenced Defendant to twelve years in prison. Defendant appealed, arguing that there was insufficient evidence to establish that his actions were voluntary and met the statutory definition of criminal negligence. The Supreme Judicial Court affirmed the judgment, holding (1) the court’s express finding that Defendant acted in a way that meets the definition of culpable negligence was supported by competent evidence in the record; and (2) the trial court found all the facts necessary to support its judgment given that those inferred findings were supported by evidence in the record. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of fourteen criminal offenses, including four counts of aggravated attempted murder. The trial court imposed multiple life sentences in addition to multiple lesser sentences, all to be served concurrently. The Supreme Judicial Court affirmed the convictions and sentences. Defendant filed a petition for post-conviction review, asserting several grounds for relief, including ineffective assistance of appellate counsel. The court denied the petition, concluding that no error by appellate counsel was sufficiently prejudicial to justify any relief. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to relief under Strickland v. Washington. View "Fortune v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of gross sexual assault, two counts of aggravated assault, and other charges. The Supreme Judicial Court affirmed the judgment, holding that the trial court (1) did not deprive Defendant of a fair trial by denying his motion for sanctions and a continuance based on the State’s late disclosure of the victim’s medical records; (2) did not violate Defendant’s right of confrontation when it admitted a recorded interview of the victim; and (3) did not deprive Defendant of a fair trial by precluding him from calling two late disclosed witnesses not included on the witness list described to the jury. View "State v. Gagne" on Justia Law

After a jury trial, Defendant was found guilty of unlawful trafficking of scheduled drugs and unlawful possession of scheduled drugs. The court entered judgment on the verdict and ordered the criminal forfeiture of $543 found in Defendant’s possession at the time of his arrest. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress the evidence obtained after an inventory search despite the officer’s failure to consciously apply the police department’s inventory and towing policy; (2) the trial court did not abuse its discretion when it excluded testimony by the arresting officer on the basis that the testimony was hearsay; (3) the trial court did not abuse its discretion when it denied Defendant’s motion to reopen the evidence; and (4) the trial court did not err in ordering the forfeiture of Defendant’s money. View "State v. Fox" on Justia Law

After a jury trial, Defendant was found guilty of operating under the influence (class B). Defendant appealed, arguing that the trial court abused its discretion in granting the State’s motion in limine to exclude as irrelevant the finding of an administrative hearing examiner that Defendant’s Intoxilyzer test results were unreliable due to improper pre-test observation by police. The trial court excluded the evidence pursuant to Me. R. Evid. 403. The Supreme Judicial Court affirmed, holding that the trial court properly determined that the probative value of the exclude evidence was substantially outweighed by the danger of unfair prejudice. View "State v. Renfro" on Justia Law

Defendant was charged with operating under the influence. After a trial, the court concluded that the jury was genuinely deadlocked and sua sponte declared a mistrial due to manifest necessity. Defendant then moved to dismiss the criminal complaint against him on double jeopardy grounds and on the grounds that the prosecutor had committed misconduct. The court denied Defendant’s motion to dismiss, concluding that the double jeopardy clauses of the federal and state constitutions did not bar a second prosecution and that there had been no prosecutorial misconduct. The Supreme Judicial Court affirmed, holding (1) there was a manifest necessity for a mistrial due to a genuinely deadlocked jury; and (2) Defendant’s allegations of prosecutorial misconduct were unfounded. View "State v. Jandreau" on Justia Law

After a nonjury trial, Defendant conceded that he had committed the offense of operating a vehicle with an expired registration. The trial court trial court adjudicated Defendant to have committed the traffic infraction of failing to register his vehicle for a period of between thirty and 150 days after his previous registration had expired. The Supreme Judicial Court affirmed, holding (1) the trial court did not err by denying Defendant’s request for a jury trial; and (2) there was no error in the trial court’s handling of Defendant’s various requests for accommodation for his claimed disabilities. View "State v. Chase" on Justia Law

Appellant was convicted of murdering a sixteen-year-old girl. The Supreme Judicial Court affirmed. This appeal concerned Appellant’s second petition for postconviction review, which asserted sixteen grounds. The first five grounds asserted that the attorney who represented Appellant in his first petition for postconviction review was ineffective in several respects. The trial court dismissed those grounds, concluding (1) Maine law does not permit a second petition to challenge the effectiveness of counsel who represented a petition in a prior petition; and (2) the United States Supreme Court’s decision in Martinez v. Ryan was not retroactive and, therefore, had no effect on Appellant’s first petition, which was denied before Martinez was decided. The court then denied the remainder of Appellant’s petition after an evidentiary hearing. The Supreme Judicial Court affirmed, holding that Martinez did not provide Appellant with the right to challenge the effectiveness of postconviction counsel in a subsequent postconviction review petition. View "Reese v. State" on Justia Law

Defendant was charged by complaint with operating under the influence based in part on an allegation of a blood test measuring 0.15 grams of alcohol per 100 milliliters of blood. Defendant moved to suppress the evidence obtained through the blood test. The trial court granted the motion to suppress, finding that the police officer did not obtain a warrant or seek Defendant’s consent, that Defendant did not consent to the blood test, and that there were no exigent circumstances generating an exception to the warrant requirement. The State appealed. The Supreme Judicial Court affirmed, holding that the record did not compel a finding that Defendant objectively manifested consent to the drawing and testing of his blood through his mere acquiescence and cooperation. View "State v. Boyd" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and theft by deception. Defendant appealed, arguing (1) the evidence presented at trial was insufficient to support the convictions, and (2) the trial court violated her right to be free from double jeopardy by convicting and sentencing her on both counts of theft without consolidating them. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support both convictions; and (2) the trial court did not err by entering a judgment of conviction on each count of theft or by sentencing Defendant on both counts of theft, and furthermore, there was no violation of Defendant’s right to be free from double jeopardy because the convictions and sentences were not based on a single criminal act. View "State v. Hayward" on Justia Law