Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of domestic violence assault with prior convictions. Defendant appealed, arguing that there was insufficient evidence to convict him of domestic violence assault. Specifically, Defendant argued that the State did not prove beyond a reasonable double that he and the victim were “sexual partners,” which is an element of the offense. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support the finding that Defendant and the victim were or had been “sexual partners,” and thus were “family or household members,” which is an element of the offense. View "State v. Murphy" on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to forty-two years’ imprisonment. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in admitting into evidence an audio recording of Defendant’s interview with a police detective, as its admission did not violate Me. R. Evid. 802 and 403, did not allow improper prosecutorial vouching, and did not result in prejudice; and (2) the trial court did not err in admitting evidence that Defendant had assaulted the victim hours before she was killed, as the evidence’s admission did not violate Rule 403, and the court’s limiting instruction was sufficient to satisfy Mont. R. Evid. 404(b). View "State v. Pratt" on Justia Law

After a jury trial, Defendant was convicted of one count of gross sexual assault and fifteen counts of unlawful sexual contact. Defendant later filed a petition for post-conviction review, claiming that trial counsel was ineffective by failing to seek a continuance of the sentencing hearing when Defendant was allegedly incompetent and was unable to exercise his right of allocution due to his emotional state. The court denied the petition. The Supreme Judicial Court affirmed, holding that the evidence did not compel the court to find that Defendant was deprived of constitutionally effective assistance when his trial counsel proceeded with, rather than sought to continue, the sentencing hearing despite Defendant’s confused and emotional state. View "Middleton v. State" on Justia Law

After a nonjury trial, Defendant was convicted of operating under the influence (OUI) enhanced with one prior OUI conviction. Defendant appealed, arguing, among other things, that the trial court erred by allowing the arresting officer to testify about Defendant’s statements and the officer’s observations indicating Defendant’s impairment from drugs other than alcohol because the officer lacked sufficient training or expertise in drug impairment recognition and could not perform certain evaluations that a drug recognition expert could have. The Supreme Court affirmed, holding (1) any deficiencies in an officer’s training or expertise goes to the weight, but not the admissibility, of the officer’s testimony regarding observations of impairment; and (2) the trial court in this case did not err in admitting the arresting officer’s testimony regarding his observations and the results of the field sobriety tests, as the officer was qualified to testify as to his observations, that evidence was relevant to the OUI charge, and its admission was not otherwise barred. View "State v. Atkins" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence (OUI). The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support the jury’s verdict; (2) the trial court did not abuse its discretion in refusing to grant a mistrial after the State’s attorney asked Defendant about prior interactions with police officers in the context of OUI offenses, as the State’s attorney did not ask the question in bad faith; and (3) the trial court did not commit prejudicial error by using a jury verdict form, as the use of the verdict form was entirely appropriate. View "State v. Fay" on Justia Law

Appellant was indicted in Cumberland County for burglary and theft by unauthorized taking or transfer. Appellant pleaded nolo contendere to Class C theft by unauthorized taking or transfer. Appellant was subsequently indicted in York County for theft by receiving stolen property. The two indictments concerned the taking of items from a residence in South Portland and the sale of the items in Biddeford. The second case was resolved by a plea agreement. In January 2014, Appellant filed a petition for post-conviction relief from the York County conviction and sentence, claiming that his trial counsel in the York County matter had rendered ineffective assistance by failing to move the York County indictment on double jeopardy grounds. The trial court denied Appellant’s request for relief, concluding that different conduct formed the basis of the Cumberland and York County cases. The Supreme Judicial Court vacated the trial court’s judgment denying Appellant post-conviction relief, holding (1) the second indictment charged Appellant with the same offense for which he had already been convicted and punished; and (2) trial counsel’s failure to seek dismissal of the York County indictment established that Appellant was deprived of his right to effective assistance of counsel. View "Ayotte v. State" on Justia Law

Defendant entered a conditional plea of nolo contendere to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained as a result of a stop of his vehicle and after his subsequent arrest and Intoxilyzer test. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that the traffic stop was based on reasonable articulable suspicion; and (2) the evidence was sufficient to establish that the law enforcement officer had probable cause to arrest Defendant and subject him to an Intoxilyzer test. View "State v. Morrison" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence. Defendant was sentenced to four days in jail, an $800 fine, and a ninety-day license suspension. Defendant appealed, arguing that the evidence presented at trial was insufficient to support his conviction because no rational jury could find that he operated or attempted to operate his vehicle. The Supreme Court affirmed, holding that the evidence was sufficient to support the conviction, as a rational jury could have found, beyond a reasonable doubt, that Defendant, while impaired, either drove his car to its resting place or attempted to drive his car after a law enforcement officer woke him up. View "State v. Belhumeur" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer. The Supreme Court affirmed the judgment of conviction, holding (1) the evidence was sufficient to support the theft conviction; (2) the trial court did not err in admitting into evidence several emails between Defendant and representatives of the named victims; (3) no advice-of-counsel instruction should have been given, and any error in the actual instruction given was harmless; (4) the trial court did not err in denying Defendant’s motion for a bill of particulars; and (5) the indictment in this case was not duplicitous and was properly charged. View "State v. Flynn" on Justia Law

After a bench trial, Defendant was convicted of crimes stemming from his alleged illegal possession of digital images and videos depicting the sexual assault or exploitation of children. Defendant appealed, arguing that there was insufficient evidence to sustain the convictions for two counts of possession of sexually explicit material. The Supreme Court affirmed, holding that, given the evidence presented at trial, and applying the plain meaning of the statute in effect at the time of the crimes, the trial court’s findings were supported by competent evidence in the record, and the facts supported the court’s finding of guilt beyond a reasonable doubt. View "State v. Wilson" on Justia Law