Justia Maine Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of gross sexual assault and two counts of unlawful sexual contact, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the district court did not abuse its discretion in denying Defendant's motion for a continuance; (2) there was no constitutional error in the trial court's ruling requiring that participants in Defendant's trial be masked; (3) there was no prosecutorial error in either the State's opening or closing argument or in the State's rebuttal argument; and (4) Defendant's claims of evidentiary error were unavailing. View "State v. Hunt" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder and his thirty-five-year sentence, holding that Defendant was not entitled to relief on his allegations of error.After a jury trial, Defendant was convicted of murder and robbery of the same victim. On remand, the trial court sentenced Defendant to thirty-five years for the murder conviction and twenty tears for the robbery conviction, to be served concurrently. The Supreme Judicial Court affirmed, holding (1) the lower court did not violate Defendant's constitutional rights to a sentence proportional to the offense in imposing the sentence; and (2) the lower court did not obviously err in failing to provide the jury a self-defense instruction under Me. Rev. Stat. 108(2)(A)(2). View "State v. Asante" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated the judgment of the post-conviction review (PCR) court denying Appellant's PCR petitions, holding that the PCR court misconstrued aspects of the relevant law.In his speedy trial petitions, Defendant argued that his rights to a speedy trial had been violated and that his trial counsel provided ineffective assistance by failing to raise his speedy trial claims. The PCR court denied the petition. Thereafter, Defendant sought a certificate of probable cause. The Supreme Judicial Court vacated the judgment below, holding (1) the PCR court utilized a faulty analysis in concluding that there was no merit to Defendant's speedy trial claim; and (2) because the PCR court did not analyze counsel's strategy in failing to assert Defendant's right to a speedy trial the case must be remanded. View "Winchester v. State" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of one count of aggravated trafficking in scheduled drugs and two counts of criminal forfeiture, holding that the trial court did not err in denying either Defendant's motion to suppress or his motion for discovery.On appeal, Defendant argued that the trial court erred when it denied his motion to suppress and his request for additional discovery relating to the State's cooperating defendant. The Supreme Judicial Court affirmed, holding (1) law enforcement agents had probable cause to support their stop of Defendant, and therefore, the trial court did not err when it denied Defendant's motion to suppress; and (2) the trial court did not abuse its discretion in denying Defendant's discovery motion. View "State v. Lepenn" on Justia Law

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The Supreme Judicial Court vacated the series of consecutive sentences imposed by the trial court upon Appellant's guilty pleas to ten counts of aggravated attempted murder and other crimes, holding that the trial court did not make the factual findings required for the imposition of consecutive sentences.Appellant pleaded guilty to ten counts of aggravated attempted murder, one count of robbery, one count of failure to stop, and one count of theft. The trial court sentenced Appellant to an aggregate of 225 years of incarceration, with no less than thirty years to be served. The State later agreed that the sentence imposed was unlawful. The Supreme Judicial Court vacated the sentences, holding that the court imposed consecutive sentences without making the required findings and providing the required explanation for each conviction, in violation of Me. Rev. Stat. 17-A, 1608(1). View "State v. Murray-Burns" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction for aggravated trafficking of scheduled drugs and unlawful possession of scheduled drugs, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not commit clear error when it allowed ta confidential informant (CI) to testify regarding the manner in which he had previously met with Defendant to obtain drugs; (2) any prosecutorial error during closing argument about the role of CIs in society did not affect Defendant's substantial rights; and (3) there was no error in the jury instructions given during the proceedings below. View "State v. Osborn" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder but vacated his sentence, holding that a criminal defendant's decision to exercise his constitutional right to a trial by jury may not be considered at sentencing.After a seven-day trial at which Defendant did not testify, the jury returned a verdict of guilty to murder. After a sentencing hearing, the court found that there were no mitigating circumstances and imposed a thirty-two-year sentence. The Supreme Judicial Court vacated Defendant's sentence, holding that the trial court (1) did not err when it denied Defendant's request to provide him with access to the grand jury transcript; but (2) abused its discretion by referencing Defendant's demand for a jury trial in determining the genuineness of Defendant's claim of personal reform and contrition. View "State v. Moore" on Justia Law

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The Supreme Judicial Court affirmed the judgment convicting Defendant of two counts of gross sexual assault, holding that the trial court did not err in determining that Defendant was an "other official" under Me. Rev. Stat. 17-A 253(2)(F).Defendant was a fifty-seven-year old driving school owner who taught driver's education courses at a public high school in Skowhegan. On two occasions, Defendant picked up the victim at school in the vehicle that he used to teach students to drive, drove her to a motel, and engaged in a "sexual act" with the victim. The State charged Defendant with two counts of gross sexual assault under section 253(2)(F), under which a person is guilty if he engages in a sexual act with a student and the actor is a "teacher, employee or other official having instructional, supervisory or disciplinary authority over the student." The trial court concluded that Defendant was an "other official" of the high school and convicted him of both charges. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support the lower court's findings. View "State v. Marquis" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court dismissing Plaintiff's claims for abuse of process and wrongful use of civil proceedings, holding that the trial court erred in dismissing Plaintiff's claim for wrongful use of civil proceedings.Plaintiff sued three New York-based dentists and their dental practice (collectively, Defendants) asserting claims for abuse of process, wrongful use of civil proceedings, and punitive damages. Defendants filed a motion to dismiss for failure to state a claim pursuant to Me. R. Civ. P. 12(b)(6). The trial court granted the motion. The Supreme Judicial Court reversed in part, holding that Plaintiff's complaint stated a claim for wrongful use of civil proceedings but not for abuse of process. View "Leighton v. Lowenberg" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered upon Defendant's conditional guilty plea after the trial court denied his motion to suppress evidence obtained through a police officer's interactions with him in a convenience store parking lot, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant moved on multiple grounds to suppress evidence obtained as a result of his interactions with the police officer, arguing that he was unlawfully seized based on an unreliable anonymous tip and was directed to perform field sobriety testing without given a chance to decline. The court denied the motion to suppress. Defendant then entered a conditional guilty plea to operating under the influence. The Supreme Judicial Court affirmed, holding that the officer did not violate the United States Constitution by conducting field sobriety tests under the circumstances of this case. View "State v. Wilcox" on Justia Law