Justia Maine Supreme Court Opinion Summaries

Defendant was charged with criminal operating under the influence. Defendant moved to suppress the evidence of his roadside interactions with a game warden from the moment the game warden parked his marked patrol vehicle behind Defendant’s stopped truck, exited the vehicle, and said, “Hi. Game warden.” The trial court denied the motion to suppress, concluding that the warden did not effect a Terry stop, and therefore, Defendant was not seized within the meaning of the Fourth Amendment prior to the moment the warden observed signs of Defendant’s intoxication. The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress, holding that Defendant was not seized at any time before the warden observed signs of Defendant’s intoxication. View "State v. Ciomei" on Justia Law

After a jury-waived trial, Defendant was convicted of aggravated assault and domestic violence assault. Defendant appealed, contending that the evidence was insufficient to support his conviction for aggravated assault. Specifically, Defendant argued that a strangulation incident did not support the finding that he assaulted the victim under circumstances manifesting extreme indifference to the value of human life. The Supreme Judicial Court affirmed, holding that the victim’s testimony supported the court’s finding that Defendant applied enough force to the victim’s neck to impede her breathing, and therefore, the evidence was sufficient to support Defendant’s conviction for aggravated assault. View "State v. Saucier" on Justia Law

After a jury trial, Defendant was convicted of one count of unlawful sexual assault. Defendant later filed a petition for post-conviction review, alleging that his trial counsel failed to provide effective representation during the pretrial and trial proceedings. After a hearing, the superior court denied Defendant’s petition based on its conclusion that Defendant failed to establish that he was “actually prejudiced by any such deficiencies.” The Supreme Judicial Court vacated the post-conviction judgment and remanded for reconsideration, holding that the superior court’s decision applied a test for prejudice that did not fully implement the proper standard of prejudice established in Strickland v. Washington. View "Theriault v. State" on Justia Law

After a nonjury trial, the trial court convicted Defendant of operating while his license was suspended or revoked and sentenced him to thirty days in jail. Defendant appealed, arguing that the trial court did not have jurisdiction to enforce the laws of the “State of Maine” against him and that Maine’s law requiring each driver to hold a valid driver’s license is facially unconstitutional because it violates a purported fundamental right to travel. The Supreme Judicial Court affirmed, holding (1) state jurisdiction over an individual extends to those present within the physical bounds of the state; and (2) the state may, as a valid exercise of its police power, place limitations on the operation of motor vehicles on the state’s roads. View "State v. Pelletier" on Justia Law

After a jury trial, Appellant was found guilty of elevated aggravated assault. The trial court sentenced Appellant to serve twenty-two years in prison. The Supreme Judicial Court affirmed the conviction on direct appeal. Appellant subsequently filed an amended petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance of counsel. The superior court denied Appellant’s petition for post-conviction review, concluding that Appellant received “reasonably effective assistance” of counsel. The Supreme Judicial Court affirmed, holding that Appellant’s attorney provided reasonably effective assistance as required by Strickland v. Washington. View "Manley v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of manslaughter and aggravated leaving the scene of a motor vehicle accident. The Supreme Judicial Court affirmed the judgment, holding (1) the trial court did not abuse its discretion in denying Defendant’s motion for a change of venue due to pre-trial publicity; (2) the trial court did not err in denying Defendant’s motion for a mistrial based on testimony of her Father about statements that Defendant made in the hospital following the accident; (3) the trial court did not abuse its discretion in allowing expert testimony regarding the presence of THC metabolites in a sample of Defendant’s blood; and (4) the evidence was sufficient to support Defendant’s convictions. View "State v. Lowe" on Justia Law

After a jury trial, Defendant was found guilty of elevated aggravated assault. Defendant was sentenced to twenty-two years in prison for the elevated aggravated assault and a concurrent six months in prison for the violation of a condition of release. The Supreme Court affirmed the conviction on Defendant’s direct appeal. Defendant later filed a petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance. The post-conviction court denied Defendant’s petition. The Supreme Judicial Court affirmed the post-conviction court’s denial of Defendant’s petition, holding that the court did not err in finding that Defendant failed to demonstrate that his trial counsel did not provide “reasonably effective assistance” as required by Strickland v. Washington. View "Manley v. State" on Justia Law

After a jury-waived trial, Defendant was convicted of domestic violence assault and assault. The convictions stemmed from an altercation with Defendant’s ex-girfriend and his stepdaughter. Defendant appealed, arguing that the trial court erred in finding that the State presented sufficient evidence to disprove Defendant’s self-defense justification beyond a reasonable doubt. The Supreme Judicial Court affirmed, holding that, viewed in the light most favorable to the State, competent evidence supported the trial court’s ultimate finding that the State disproved Defendant’s self-defense justification beyond a reasonable doubt. View "State v. Fletcher" on Justia Law

After a jury trial, Defendant was convicted of tampering with a victim, aggravated furnishing of scheduled drugs, and endangering the welfare of a child. Defendant appealed, arguing that the trial court erred by denying her request that the court instruct the jury on the statutory defense of duress. The Supreme Judicial Court affirmed, holding that the court did not err in declining to instruct the jury on the statutory defense of duress as to any of the three charges because the jury could not have found facts necessary to find that Defendant’s conduct was the product of duress. View "State v. Gagnier" on Justia Law

Kevin Collins, a prison inmate, filed three grievances against the Department of Corrections relating to food services and the prison’s telephone system. The Department denied the grievances. Collins subsequently filed a petition for judicial review of a final agency action. The trial court ultimately dismissed Collins’s petition as untimely. Collins filed a notice of appeal accompanied by an application to proceed without payment of fees, thus requiring Collins to file a certified copy of his account statement for the six months preceding his appeal. Collins did not file his account statement in a timely manner. The trial court waived the appellate filing fee. The Department appealed from the order waiving the filing fee and filed a motion to dismiss Collins’s appeal for failure to file a new account statement for the six months preceding this appeal, arguing that Collins had failed to perfect his appeal. The Supreme Judicial Court (1) dismissed Collins’s appeal on the grounds that Collins failed to comply with the timing requirements of the Maine Rules of Appellate Procedure and had failed to perfect his appeal; and (2) dismissed as moot the Department’s appeal from the order waiving Collins’s appellate filing fee. View "Collins v. Dep’t of Corr." on Justia Law