Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated trafficking of scheduled drugs and refusal to submit to arrest or detention. The Supreme Judicial Court affirmed the judgment, holding (1) the trial court did not err or violate Defendant’s constitutional rights by sustaining the State’s objection to Defendant’s cross-examination of a certain witness about the nature of the locale where the crime allegedly occurred based on weaknesses in the probative value of the evidence; and (2) the trial court did not err when it denied Defendant’s motion for a judgment of acquittal, as the evidence was sufficient to support the jury’s guilty verdict. View "State v. Adams" on Justia Law

Defendant pleaded guilty to burglary and other crimes. Prior to sentencing, Defendant filed a motion to withdraw his pleas and his admission, alleging that his diagnosis of kleptomania in a presentence mental evaluation report constituted new evidence of a mental abnormality that raised a reasonable doubt as to his intent to commit the crimes charged. The trial court denied the motion. The Supreme Judicial Court affirmed, holding that the trial court did not abuse its discretion in denying Defendant’s motion to withdraw his pleas, as the evidence of kleptomania could not raise a reasonable doubt as to Defendant’s intent to commit burglary and theft, and the kleptomania diagnosis did not require the trial court to grant Defendant a discretionary withdrawal of his pleas. View "State v. Giroux" on Justia Law

Between 2002 and 2008, Defendants applied for, were found qualified for, and lived in Section 8 housing, for which the local housing authority paid a substantial rent subsidy to the landlord. Throughout this time, Defendants earned income far in excess of the maximum that would qualify them for Section 8 housing assistance. Defendants were eventually convicted of theft by deception. Defendants appealed, arguing that the trial court erred in admitting into evidence as business records certain forms on which Defendants had provided financial information. The Supreme Court affirmed the judgments, holding that the trial court did not abuse its discretion in admitting the forms into evidence. View "State v. Abdi" on Justia Law

In this “cold case,” Defendant was charged with a murder committed fifteen years before the trial. After a jury trial, Defendant was found guilty of intentional or knowing murder. The Supreme Court affirmed, holding (1) the trial court did not err in admitting prior consistent statements of Defendant’s son; and (2) the court abused its discretion in precluding Defendant from presenting certain evidence of Defendant’s son’s involvement with the murder to support an alternative suspect defense, as the court’s application of alternative suspect jurisprudence reflected a misapprehension of the concept, but the error was harmless. View "State v. Jamie" on Justia Law

After a jury trial, Defendant was found guilty of aggravated assault. The Supreme Court affirmed the judgment, holding (1) although the jury should have received complete instructions before beginning deliberations, Defendant was not unfairly prejudiced when the trial court provided additional jury instructions, after the jury had already begun deliberations, regarding an alternative means of proving aggravated assault as a lesser included offense of the charged crime of elevated aggravated assault; and (2) the trial court did not err by refusing to give a requested jury instruction on self-defense, as the evidence did not generate a self-defense instruction. View "State v. Delano" on Justia Law

After a jury trial, Defendant was convicted of one count of unlawful contact as a Class B offense and five counts of unlawful sexual contact as a Class C offense. During the trial, the prosecutor noticed that although Count IX purported to charge Defendant with a Class B offense based on the victim’s age, the time frame included in the portion of the indictment that described Count IX actually alleged that the victim had been twelve or thirteen years old on the relevant dates. The court subsequently allowed the State to amend the indictment to reduce the offense to a Class C unlawful sexual contact. Defendant appealed, arguing that the trial court erred in permitting the State to amend Count IX of the indictment. The Supreme Court affirmed the judgment as amended to correct a scrivener’s error, holding that the trial court did not err in granting the State’s motion to amend the indictment. View "State v. Thornton" on Justia Law

Defendant was charged with unlawful trafficking of scheduled drugs and seeking criminal forfeiture of cash discovered during the search of his vehicle by Maine Drug Enforcement Agency (MDEA) agents. Defendant filed a motion to suppress the evidence gathered from the search. The suppression court denied the motion, concluding that MDEA had sufficient probable cause to search the vehicle based on the totality of the circumstances. The Supreme Court affirmed, holding that because Defendant failed to show his reasonable expectation of privacy in the vehicle, his Fourth Amendment rights were not violated by the search. View "State v. Lovett" on Justia Law

In 2003, John Doe XLVI pleaded guilty to and was convicted of possession of sexually explicit material. When Doe was sentenced, possession of sexually explicit material was not a sex offense requiring registration under Maine’s Sex Offender Registration and Notification Act of 1999 (SORNA), and therefore, Doe was not ordered to comply with SORNA. Possession of sexually explicit material was subsequently added to the list of sex offenses. In 2009, the Legislature amended SORNA to provide that a duty to register “is not triggered by a court determination, but by and upon notification.” In 2012, Doe received a notice of the duty to register. Doe filed this action seeking to enjoin the State from pursuing criminal charges against him for failing to register, alleging, inter alia, that SORNA was an invalid bill of attainder. The superior court rejected Doe’s challenges. The Supreme Court vacated the judgment of the trial court, holding that SORNA is punitive as to offenders who were not sentenced to comply with SORNA when SORNA registration was part of sentencing and who were subsequently subjected to SORNA registration when their earlier offenses were added to the statutory list of sex offenses and registration was removed from sentencing. View "John Doe XLVI v. Anderson" on Justia Law

Jeffrey Wyman was charged with operating under the influence (OUI) and, after a jury trial, found not guilty. Jeffrey and his son, David Wyman (Defendant), both testified during the OUI trial. The instant perjury case stemmed from this testimony. Both Defendant and his father were indicted for perjury. After a jury trial, Defendant was found guilty of perjury. The Supreme Court affirmed, holding (1) because the State presented proof of the elements of perjury with respect to David’s testimony, the evidence was sufficient to support Defendant’s conviction; and (2) the trial court did not abuse its discretion in admitting cell phone billing records over Defendant’s objection. View "State v. Wyman" on Justia Law

After a jury trial, Defendant was convicted of perjury. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by allowing the State to introduce testimony regarding Defendant’s silence following his arrest for operating under the influence (OUI) and by allowing the State to refer to this testimony during closing argument; (2) Defendant failed to establish that the trial court abused its discretion in allowing a police officer to testify to his opinion that “there were lies told” during Defendant’s trial for OUI, at which Defendant was acquitted, or that the opinion was prejudicial to him; and (3) admitting the testimony of a Verizon employee about the contents of Defendant’s cell phone billing record that the State offered as the testimony of a custodian of records. View "State v. Wyman" on Justia Law