Justia Maine Supreme Court Opinion Summaries

After a bench trial, Defendant was convicted of violating Me. Rev. Stat. 12, 6575-G, which makes it a Class D crime to fish for or take elvers within 150 feet of a dam with a fishway or within 150 feet of a fishway. Defendant appealed, arguing that the district court erred in convicting him based on conduct that was not alleged in the Uniform Summons and Complaint (USC). In the USC, the State charged Defendant with “fishing for elvers within 150 feet of a dam with a fishway,” but the district court found Defendant guilty of fishing for elvers within 150 feet of a fishway, not a dam. The Supreme Judicial Court vacated the judgment, holding that the trial court’s factual findings were insufficient to support a conviction for the violation charged in the USC. View "State v. Stanley" on Justia Law

After a jury trial, Defendant was found guilty of his second offense of failing to comply with the Sex Offender Registration and Notification Act. Defendant appealed, arguing that the superior court erred in excluding relevant evidence from the Department of Public Safety, State Bureau of Identification that caused him to believe, erroneously, that he was no longer required to register. The Supreme Court vacated the judgment, holding that, to the extent that the court determined that Defendant’s purported reliance on the letter was not believable, the court made a credibility determination that should have been made by the jury, and therefore, the court erred in excluding the letter. View "State v. Reynolds" on Justia Law

Defendant pleaded guilty to two counts of misdemeanor assault and was sentenced to one year in jail and one year of probation for each of the assault counts, to be served consecutively. As a condition of probation, Defendant was prohibited from having contact with his son except as specifically permitted by the family court. Defendant filed a motion to amend the conditions of probation. The court denied the motion. Defendant appealed, arguing that the court abused its discretion because the district court, in a collateral parenting action, had already allowed him to have supervised contact with his son. The Supreme Judicial Court affirmed, holding that the court did not unconstitutionally infringe on Collins’s parental rights when it increased the restrictions on his rights of contact with his son that had been set in the separate judicial proceeding. View "State v. Collins" on Justia Law

After a jury trial, Defendant was found guilty of theft by receiving stolen property. The superior court sentenced Defendant to fourteen days in fail and a $500 fine. Defendant appealed, arguing that his sentence was disproportionate to the crime committed and in violation of his equal protection and due process rights. The Supreme Judicial Court affirmed Defendant’s sentence, holding (1) Defendant's sentence was not illegal because it fell within the lower range of the lowest quadrant of the incarceration time authorized by the Legislature for a Class D crime; (2) Defendant’s equal protection claim failed because he did not surpass the threshold requirement of proving that similarly situated individuals are not treated equally; and (3) Defendant’s sentence did not violate his right to due process where the sentence was based on factually reliable information and the court did not deprive Defendant of his opportunity to refute the information relied upon at sentencing. View "State v. Bennett" on Justia Law

After a jury trial, Defendant was found guilty of murder and sentenced to forty-five years in prison. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to law enforcement officers in the hours following the murder because he was in a state of intoxication and emotional distress at the time that rendered his statements involuntary. The Supreme Court affirmed, holding that the court did not err in determining that Defendant’s statements to law enforcement were the free choice of a rational mind, were fundamentally fair, and were not a product of coercive police conduct. View "State v. Kierstead" on Justia Law

After a bench trial, the trial court convicted Defendant of unlawful possession of scheduled drugs and ordered Defendant to forfeit his firearm to the State. Defendant filed a notice of appeal but did not request production of a transcript of the trial or submit a transcript substitute. Further, Defendant’s appendix filed with his brief contained neither a docket record of the proceedings nor the orders by which the court continued the date for trial. The Supreme Judicial Court dismissed the appeal without reaching the merits of Defendant’s arguments because Defendant failed to comply with the applicable Maine Rules of Appellate Procedure. View "State v. King" on Justia Law

In 2009, Defendant pleaded guilty to unlawful trafficking in scheduled drugs. In 2012, Defendant pleaded guilty to two counts of unlawful possession of scheduled drugs and admitted to a probation violation. Defendant was subsequently accepted into the Adult Drug treatment Court Program. In 2013, Defendant’s probation officer moved to revoke his probation, alleging that Defendant had committed new criminal conduct and had violated the conditions of his probation. After a hearing, the court found a probation violation and revoked Defendant’s probation in full. Defendant appealed, arguing that his constitutional right to a neutral and detached decision maker was violated in the Drug Court proceedings. The Supreme Judicial Court vacated the judgment without reaching the issues regarding the Drug Court processes, holding that the trial court applied an incorrect standard of proof in revoking probation. Remanded. View "State v. Power" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault and domestic violence terrorizing. Defendant appealed, arguing, among other things, that the trial court erred by failing to instruct the jury that it was required to acquit him if it found that the State failed to disprove self-defense and by failing to provide the jury with revised written instructions to correct an error in the written instructions that had been given to the jury when it began its deliberations. The Supreme Judicial Court vacated the judgment of the trial court, holding (1) the court’s instructions on self-defense suffered from two structural flaws that, taken together, rose to the level of obvious error; and (2) the prejudicial effect of the deficient instructions was compounded by the court’s decision not to give the jury corrected written instructions. Remanded. View "State v. Baker" on Justia Law

After a bench trial, Defendant was convicted of attempted kidnapping and assault. Defendant appealed, arguing, among other things, that the trial court erred in analyzing the defense of mental abnormality. The Supreme Court affirmed the conviction, holding (1) the trial court applied the correct analysis in determining whether evidence of Defendant’s purported abnormal condition of mind negated his requisite culpable state of mind; and (2) there was sufficient evidence presented at trial for the trial court to find beyond a reasonable doubt that Defendant acted with the intent to complete the crime of attempted kidnapping. View "State v. Graham" on Justia Law

In two criminal cases, Defendant was indicted on several charges, including unlawful trafficking in synthetic hallucinogenic drugs and conspiracy to commit unlawful trafficking in synthetic hallucinogenic drugs. Defendant filed a motion to dismiss the two cases, arguing that the statute defining a “synthetic hallucinogenic drug” is unconstitutionally vague. The superior court denied the motions to dismiss. Defendant subsequently entered conditional guilty pleas. The Supreme Court affirmed, holding (1) the term “derivative” used in the statute is not unconstitutionally vague; and (2) the statute as a whole is not unconstitutionally vague. View "State v. Reckards" on Justia Law