Justia Maine Supreme Court Opinion Summaries

While he was an inmate, Defendant was charged with ten counts of assaulting an officer. Defendant was found not criminally responsible by reason by mental disease or defect and was ordered committed to the custody of the Commissioner of the Department of Health and Human Services (DHHS). Defendant’s prison sentence was tolled while he remained committed. Approximately five years later, the superior court ordered Defendant to be discharged from DHHS custody, finding by clear and convincing evidence that he no longer suffered from a mental disease or defect. Defendant was subsequently remanded to the custody of the Department of Corrections to serve the remainder of his prison sentence. The Supreme Court affirmed, holding that the evidence supported the trial court’s finding, by clear and convincing evidence, that Defendant’s dangerousness was not the result of a mental disease or defect and that, therefore, DHHS could no longer maintain Defendant in its custody. View "James v. State" on Justia Law

Defendant pleaded guilty in federal court to sexual exploitation of a child and possession of child pornography. Before sentencing, a state grand jury indicted Defendant on thirteen counts of gross sexual assault. Defendant pleaded not guilty to all of the gross sexual assault charges. After the federal district court sentenced Defendant, Defendant filed a motion to dismiss the State’s indictments for gross sexual assault, arguing that the State’s prosecution subjected him to double jeopardy. The trial court denied the motion to dismiss. The Supreme Judicial Court affirmed, holding (1) even if the State’s current prosecution subjects Defendant to the risk of being punished twice for the same conduct, such duplicative punishment is constitutional when, as in this case, the punishments are imposed by separate sovereigns; and (2) there is no evidence to sustain Defendant’s contention that an exception to the “dual sovereignty” doctrine of double jeopardy jurisprudence applied in this case. View "State v. Hoover" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

After a jury trial, Defendant was found guilty of two counts of gross sexual assault. Defendant appealed, arguing that his due process rights were violated by the State’s failure to preserve a recording of a police interview of the victim and by the State’s twenty-two-year delay between the alleged assaults and the indictment. The Supreme Judicial Court affirmed the judgment, holding (1) Defendant did not prove the elements necessary to establish a violation of his constitutional rights due to the State’s loss of evidence where the missing recording was not apparently exculpatory at the time it was lost and because the State did not act in bad faith in causing its disappearance; and (2) the trial court did not err in finding that Defendant failed to meet his burden of proving prejudice from the pre-indictment delay. View "State v. Cote" on Justia Law

After a jury trial, Defendant was convicted of tampering with a juror and violating a condition of release. The trial court imposed a sentence of two years in prison. The Supreme Judicial Court affirmed, holding that the trial court did not err by (1) denying Defendant’s motion to dismiss the indictment; (2) defining the term “juror” in the jury instructions; and (3) allowing lay witnesses to testify about whether they thought Defendant was trying to influence them by holding up sign in view of twenty-five to thirty potential jurors before crumpling up the piece of paper and discarding it. View "State v. Solomon" on Justia Law

Defendant was indicted on one count of unlawfully trafficking in scheduled drugs and one count of illegal importation of scheduled drugs. Defendant filed a motion to suppress as evidence illegal drugs seized from him by law enforcement officers after they stopped a vehicle in which he was a passenger. The trial court granted the motion to suppress, concluding that the warrantless search of the clothes Defendant was wearing exceeded the bounds of a valid protective search or justifiable search for contraband. The Supreme Court vacated the suppression order, holding that the search was justified by probable cause and the existence of exigent circumstances, and therefore, the search was constitutional. Remanded. View "State v. Martin" on Justia Law

In 1989, Appellant was convicted of kidnapping, sexual assault, and murder. In 2008, Appellant filed a motion for a new trial pursuant to Maine’s amended DNA analysis statute. After a hearing, the superior court denied Appellant’s motion for a new trial, concluding that Appellant had not met his burden of showing by clear and convincing evidence that a new trial would probably result in a different verdict. The Supreme Judicial Court affirmed, holding that the superior court did not err or abuse its discretion in (1) finding that Appellant failed to prove that the new DNA evidence admitted at the hearing, when considered with all the other evidence in the case, both old and new, would make it probable that a different verdict would result from a new trial; (2) limiting the evidence that Appellant could present at the hearing to evidence concerning the new DNA testing and analysis; and (3) denying Appellant’s motion to recuse. View "State v. Dechaine" on Justia Law

After the trial court denied Defendant’s motion to suppress evidence derived from internet service provider (ISP) records that the State obtained with a grand jury subpoena, Defendant entered a conditional guilty plea to a charge of possession of sexually explicit materials. Defendant appealed, arguing that the State was required to use the procedure set forth in Me. Rev. Stat. 5, 200-B to obtain the ISP records and that its failure to do so violated his due process rights. The Supreme Court affirmed, holding that section 200-B creates an alternative, not exclusive, method for it to use in seeking ISP records, and therefore, the trial court did not err in finding that the State was not barred from using a grand jury subpoena in obtaining the ISP records. View "State v. Bragdon" on Justia Law

After a jury trial, Defendant was convicted of assault on an officer, violation of a protective order, and refusing to submit to arrest. The Supreme Judicial Court affirmed the judgment of conviction, holding that the superior court did not err or abuse its discretion by (1) allowing testimony about the violent details of a prior unrelated incident; and (2) denying Defendant’s motion for a mistrial after the State made certain improper remarks in its opening statement, as any prejudice resulting from the prosecutor’s improper remarks was adequately remedied by the court’s response. View "State v. Begin" on Justia Law

After a jury trial, Defendant was convicted of several counts of unlawful sexual contact, criminal attempt, visual sexual aggression against a child, sexual misconduct with a child under twelve, and unlawful sexual touching. Defendant appealed, arguing that the superior court erred in admitting and excluding various pieces of evidence and in denying his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) the admission of approximately forty specific statements from each of the State’s witnesses’ testimony was not obvious error; and (2) Defendant’s remaining contentions were similarly without merit. View "State v. Vultee" on Justia Law