Justia Maine Supreme Court Opinion Summaries

Defendant pleaded unconditionally guilty to a charge of receiving stolen property. The trial court accepted the open plea, which Defendant never moved to withdraw. Defendant appealed. The State moved to dismiss the appeal on the ground that Defendant cannot take a direct appeal from his plea of guilty absent a challenge to the trial court’s jurisdiction or the constitutionality of his punishment. The Supreme Court granted the motion and dismissed the appeal because Defendant pleaded guilty unconditionally, did not move to withdraw his plea, and did not contend that the trial court lacked jurisdiction or that it imposed an unconstitutional sentence. View "State v. Stevens" on Justia Law

Defendant pleaded guilty to three counts of gross sexual assault and two counts of unlawful sexual contact. The court sentenced Defendant to twenty years’ imprisonment followed by fifteen years of supervised release. Defendant challenged his sentence on appeal, arguing, inter alia, that the supervised release sentencing process, mandated by law, violates the due process clause and the double jeopardy clause. The Supreme Judicial Court affirmed, holding (1) Defendant’s due process argument actually addresses the length of his total sentence, and the sentence is not constitutionally disproportionate or cruel or unusual punishment; (2) the supervised release sentencing process does not violate the Double Jeopardy Clause; and (3) the supervised release statutory scheme does not abrogate the traditional Hewey analysis. View "State v. Parker" on Justia Law

Defendant pleaded guilty of burglary and theft by unauthorized taking or transfer. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements made during a police interview while he was detained in county jail awaiting a court appearance for a probation violation on an unrelated charge because he was not provided with Miranda warnings prior to a custodial interview. The Supreme Judicial Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress because Defendant was not in custody within the meaning of Miranda when he was interviewed by detectives. View "State v. Ames" on Justia Law

After a jury trial, Defendant was convicted of one count of arson. The conviction stemmed from a fire that largely destroyed a diner run by Defendant. Defendant appealed, arguing, inter alia, that the trial court erred by admitting expert testimony concerning the cause of the fire. The Supreme Judicial Court affirmed, holding (1) the trial court did not clearly err by admitting the expert opinion testimony concerning the cause of the fire; (2) the trial court did not abuse its discretion by allowing Defendant’s acquaintance to testify about statements he made to Defendant about how to start house fires; and (3) the evidence was sufficient to establish that Defendant intentionally set the fire. View "State v. Maine" on Justia Law

Defendant entered conditional guilty pleas to three drug-related crimes. Defendant appealed, arguing (1) the information contained in the warrant application to search his home was insufficient to allow a probable cause determination; (2) the court erred in allowing only the State to present evidence at a preliminary hearing that the court considered when denying Defendant’s motion for a Franks hearing; and (3) he made a substantial preliminary showing that entitled him to a Franks hearing. The Supreme Court vacated the judgment, holding (1) the trial court correctly denied that part of Defendant’s motion to suppress challenging probable cause; but (2) the hearing conducted by the trial court must be treated as the beginning of a Franks hearing, and therefore, the court erred by holding a hearing that did not allow Defendant to attempt to meet the burden of production necessary for a full Franks hearing. Remanded for the court to hold a full Franks hearing. View "State v. Thompson" on Justia Law

Defendant pleaded guilty to one count of robbery. Defendant later admitted to four violations of his probation. The court enrolled Defendant in drug court. After he entered the program, Defendant again violated the conditions of his probation. Following a hearing to determine whether to expel Defendant from the drug court program, the court revoked Defendant’s probation and imposed a sentence of five years. Defendant filed a petition for post-conviction review, arguing that his due process and equal protection rights had been violated at the drug court termination hearing. The State moved to dismiss Defendant’s petition based on a lack of subject matter jurisdiction, arguing that Me. Rev. Stat. 15, 2121, 2124 expressly barred post-conviction review of a probation revocation. The court denied the State’s motion to dismiss and granted Defendant’s petition for post-conviction review. The Supreme Court vacated the judgment and remanded with instructions to dismiss the petition for post-conviction review, holding (1) in this case, the proper path to obtain review is to file a notice of appeal; and (2) the court did not abuse its discretion in expelling Defendant from drug court and revoking his probation. View "Spinney v. State" on Justia Law

After a jury trial, Defendant was convicted of baiting deer and hunting from an observation stand overlooking deer bait. The Supreme Court affirmed, holding (1) the instructions given by the trial court fairly and accurately informed the jury of all necessary elements of the governing law, and therefore, Defendant was not deprived of a fair trial; and (2) statements by the prosecutor during his opening and closing that purported to explain that hunting regulations and statutes were premised on a need to keep a level playing field among hunters were improper, but the error was not plain, nor did the error affect Defendant’s substantial rights or the outcome of the trial. View "State v. Lajoie" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence with one prior conviction. Defendant appealed, arguing that the trial court abused its discretion by excluding testimony that certain chemicals could have resulted in a falsely elevated breath-alcohol test if they were present in Defendant’s system when he took the breath test. The Supreme Court affirmed, holding that, under the particular factual circumstances of this case, the trial court did not abuse its discretion by excluding the testimony about the effect of those chemicals on breath-testing equipment and test results produced by that equipment because there was not a sufficient factual foundation to link the testimony with the facts of this case. View "State v. Rourke" on Justia Law

Petitioner filed a petition in the superior court challenging a disciplinary decision by the Department of Corrections. The superior court dismissed the petition, concluding that Petitioner failed to state a claim where the court could not “determine its jurisdiction in the absence of its determination of the date of the final agency action.” Petitioner later filed a motion pursuant to Me. R. Civ. P. 60(b) to set aside the order dismissing his petition. The superior court denied the Rule 60(b) motion. The Supreme Judicial Court vacated the judgment, holding that the superior court erred in dismissing the petition for lack of jurisdiction because the court improperly required that the petition include content not statutorily required and presumed a lack of jurisdiction without a basis to do so. Remanded. View "Mutty v. Department of Corrections" on Justia Law

Defendant entered a conditional guilty plea to a charge of unlawful possession of schedule W drugs, preserving his right to appeal from the denial of his motion to suppress. Defendant appealed, arguing that the trial court erred by denying his motion to suppress evidence of drugs that he was carrying in a body cavity because law enforcement officers exceeded the authority granted them by two search warrants explicitly authorizing a search of Defendant’s person. The Supreme Court affirmed, holding that, under the facts of this case, the trial court did not err in denying the motion to suppress. View "State v. Cooper" on Justia Law