Justia Maine Supreme Court Opinion Summaries

Following a jury trial, Defendant was convicted of burglary, theft by unauthorized taking, and violation of a condition of release. The court imposed an aggregate sentence of seven years’ imprisonment. On appeal, Defendant argued, inter alia, that the trial court effectively prevented him from testifying when, prior to trial, it reserved ruling on the extent to which the State would be permitted to impeach his potential testimony. The Supreme Court affirmed, holding (1) the trial court did not obviously err in declining to give Defendant a pretrial ruling; and (2) the evidence was sufficient to support the jury’s verdict. View "State v. Perkins" on Justia Law

In 2013, pursuant to the Freedom of Access Act (FOAA), Phillip Bowler requested a copy of the Attorney General’s investigative file concerning a death that occurred in 1953. The Deputy Attorney General denied Bowler access to the file on the ground that it was designated confidential by statute. Bowler appealed to the superior court. The superior court denied the appeal. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the file was made confidential by statute; (2) the Attorney General did not waive the statutory confidentiality of the file by releasing a copy to the decedent’s family; and (3) Defendant’s argument that releasing the file to a family member but not to him violated his constitutional right to equal protection failed. View "Bowler v. State" on Justia Law

After a jury trial, Defendant was convicted for operating after revocation. The Supreme Court affirmed the judgment as amended, holding (1) any error by the trial court in refusing to instruct the jury about certain statutory requirements applicable to written notices of revocation was harmless; and (2) even if the State improperly offered and used documents that Defendant alleged were not properly identified as part of an exhibit but nonetheless were presented to the jury did not rise to the level of obvious and reversible error. Remanded for correction of an improper statutory reference in the judgment and commitment order. View "State v. Garcia" on Justia Law

Defendant was at the place of his employment when his employer asked him to submit to a breath test. The results from the employer’s self-contained portable breath-alcohol testing device showed that Defendant had indicators of alcohol in his system, and Defendant was sent home on unpaid leave. Defendant was driving his van after leaving his place of employment when he was stopped and arrested. A police officer administered several field sobriety tests after stopping Defendant. Defendant was subsequently charged with driving under the influence. Before trial, the court granted the State’s motion in limine to exclude any evidence of the workplace breath-alcohol test to challenge the accuracy of the State’s intoxilyzer test. Defendant entered a conditional guilty plea to the charge then appealed the order on the motion in limine. The Supreme Court vacated the judgment, holding that Defendant was entitled to challenge the reliability of the test results offered by the State by any appropriate means that is otherwise admissible in evidence, and thus the trial court denied Defendant the opportunity to make a formal offer of proof by excluding evidence of the workplace breath-alcohol test. View "State v. Adams" on Justia Law

Defendant was charged with three Class E offenses. Defendant posted $500 cash bail in those matters and was assigned an attorney after the court found him indigent. While released on bail, Defendant was indicted on aggravated trafficking of scheduled drugs. Defendant moved for an assignment of counsel in the aggravated trafficking matter. The court granted the motion and ordered that the $500 bail he previously posted be applied to his attorney fees. Following an appeal in which Defendant was represented by his court-assigned attorney, the Supreme Court vacated Defendant’s conviction, and Defendant was acquitted of the aggravated trafficking charge. Defendant’s Class E charges were ultimately dismissed. Defendant then requested the return of his $500 cash bail in the Class E matters. The motions were denied on the grounds that the bail had been applied to counsel fees. The Supreme Court affirmed, holding that even though Defendant was eventually acquitted of the aggravated trafficking charge and his other charges were dismissed did not mean he was relieved of his obligation to pay the ordered portion of his attorney fees. View "State v. Lowden" on Justia Law

After a jury trial, Defendant was convicted of numerous crimes, including two counts of aggravated trafficking of scheduled drugs. The charges stemmed from events that occurred on four different dates - three dates in July and August 2012 and one date in September 2012. On appeal, Defendant argued that the superior court abused its discretion in denying his motion to sever the counts arising from the July and August events from the counts arising from the September events. The Supreme Court affirmed, holding that that superior court did not abuse its discretion in denying Defendant relief from joinder, as, under the circumstances of this case, Defendant failed to make the necessary showing of unfair prejudice required to warrant severance. View "State v. Olmo" on Justia Law

After a jury trial, Defendant was convicted of aggravated trafficking in scheduled drugs, among other crimes. The Supreme Court affirmed the judgment, holding (1) the evidence was sufficient to support the conviction; (2) the State proved all of the elements of aggravated trafficking where the parties signed a stipulation as to Defendant’s prior conviction for a similar offense but the State failed to formally introduce the stipulation on the record; and (3) the trial court committed plain error by instructing the jury that it did not have to find that the manufacturing process had been completed in order to convict Defendant of the trafficking offense, but the error did not constitute obvious error. View "State v. Fox" on Justia Law

The trial court revoked Defendant’s probation based on findings that Defendant committed the new crimes of burglary and theft. Defendant appealed, arguing that the trial court erred by admitting, for the purpose of revoking Defendant’s probation, a police officer’s testimony about Defendant’s confessions despite the fact that the statements were obtained in violation of the procedural safeguards established to protect an individual’s Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed the judgment, holding that the exclusionary rule does not apply to probation revocation proceedings unless the probationer presents proof of widespread police harassment or other proof of a serious due process violation. View "State v. Johansen" on Justia Law

Defendant pleaded not guilty to passing a stopped school bus in violation of 29-A Me. Rev. Stat. 2308(2). After a bench trial, the trial court found Defendant guilty and imposed a $250 fine. Defendant filed a motion for findings of fact, which was denied. Defendant then appealed, arguing that “meeting or overtaking a school bus from either direction” means that the statute’s commend to stop applies when a school bus is approached from the front or the rear but not when the bus is approached from the side at a "T" intersection, as occurred in this case. The Supreme Court affirmed the conviction, holding that the trial court did not err in rejecting Defendant’s interpretation of the statute and in finding Defendant guilty as charged. View "State v. Mourino" on Justia Law

Defendant entered a conditional guilty plea to stealing drugs, and judgment was entered accordingly. The Supreme Court affirmed the judgment, holding (1) the court did not err in denying Defendant’s motion to suppress her confession, which was made to police during a voluntary polygraph, as the Defendant’s right to counsel in a separate, prior prosecution did not apply to interrogations arising out of the subsequently, separately alleged offenses; and (2) the pre-charge interrogation regarding the new criminal conduct that gave rise to the current prosecution was not a “critical stage” of the prosecution for purposes of the Sixth Amendment. View "State v. Babb" on Justia Law