Justia Maine Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Appellant was found guilty of the murder of the mother of his child. Appellant was sentenced to fifty-five years in prison and ordered to pay restitution. The Supreme Court affirmed the conviction. Appellant filed a pro se petition for post-conviction review, alleging that the trial court violated his right to a public trial. The post-conviction court denied the motion, concluding that Appellant’s Sixth Amendment right to a public trial was not violated. The Supreme Court affirmed, holding (1) trial counsel did not provide ineffective assistance by agreeing to the process of conducting certain aspects of voir dire in chambers, and appellate counsel did not provide ineffective assistance by failing to raise Appellant’s Sixth Amendment claim on direct appeal; (2) the policy of prohibiting spectators from wearing certain types of apparel in the courthouse did not constitute a partial closure of the courtroom; (3) the trial court’s decision to prohibit members of the public from entering the courtroom during witness testimony did not constitute a partial closure; and (4) the post-conviction court properly found that the public was not excluded from the announcement of the verdict. View "Roberts v. State" on Justia Law

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After a jury trial, Defendant was convicted of assault and domestic violence assault and sentenced to three years’ imprisonment. The convictions stemmed from an altercation Defendant had with his fourteen-year-old son. Defendant appealed, arguing that his conviction should be vacated the State did not produce sufficient evidence to overcome the “parental-control” justification, under which parents may use a “reasonable degree of force” in disciplining their children. The Supreme Court affirmed, holding that there was sufficient evidence presented at trial for the jury to rationally conclude that Defendant’s actions exceeded the bounds of parental discipline and became criminal in nature. View "State v. Treadway" on Justia Law

Posted in: Criminal Law
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In 2011, the State charged Defendant of aggravated assault and attempted murder. The State alleged that while Defendant and his wife, Lisa, were hiking on Megunticook Mountain, Defendant struck Lisa in the head, dragged her to the edge of a cliff, and threw her over the edge. Shortly thereafter, Defendant was seriously injured after himself falling from a cliff. Defendant was treated at Eastern Maine Medical Center for several days. In 2012, the State obtained a search warrant to obtain Defendant’s personal medical records from the hospital. Defendant filed a motion to suppress his medical records or, in the alternative, to dismiss the charges against him, contending that the State failed to use the proper procedure in obtaining his records, the search warrant was overbroad and not supported by probable cause, and the use of the search warrant during his criminal proceeding violated his due process rights. The trial court declined to suppress Defendant’s medical records. The Supreme Court dismissed Defendant’s appeal as interlocutory, holding that the trial court’s decision not to suppress the evidence did not give rise to a right to an interlocutory appeal. View "State v. Black" on Justia Law

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After a jury trial, Defendant was convicted of one count of gross sexual assault. On appeal, Defendant argued that the trial court committed obvious error by permitting the State to introduce evidence of his pre-arrest refusal to voluntarily submit to a warrantless collection of a DNA sample and to argue to the jury that it could infer consciousness of guilt from the refusal. The Supreme Court vacated the judgment, holding that the trial court committed obvious error in admitting evidence of Defendant’s refusal to submit to the warrantless search for the purpose of proving consciousness of guilt. Remanded.View "State v. Glover" on Justia Law

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After a bench trial, Defendant was convicted of criminal trespass for entering a Rite Aid store six months after a police officer ordered Defendant not to be on the premises. Defendant appealed, arguing that the State failed to prove that he violated the criminal trespass statute because the officer was not “authorized” under the meaning of the statute to order Defendant not to enter the Rite Aid. The Supreme Court affirmed the judgment, holding that the evidence was sufficient for the fact-finder to rationally infer, beyond a reasonable doubt, that the officer was authorized by Rite Aid, and within the meaning of the criminal trespass statute, to order Defendant not to enter the Rite Aid store.View "State v. Sanchez" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of two counts of gross sexual assault and suspended to twenty years imprisonment. On appeal, Defendant argued that the evidence was insufficient to sustain his convictions, that the prosecutor engaged in impermissible misconduct, and the trial court erred in determining his sentence. The Supreme Court vacated the judgments of conviction, holding (1) the prosecutor violated the state and federal Constitutions by eliciting testimony that Defendant did not return phone calls from police and by arguing to the jury that Defendant’s pre-arrest silence demonstrated consciousness of guilt, and the error seriously affected the fairness and integrity of the judicial proceedings; and (2) the prosecutor committed misconduct by vouching for witness credibility even after the court determined that the statements were impermissible, and the error was not harmless.View "State v. Lovejoy" on Justia Law

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After a six-day jury trial, Defendant was convicted of gross sexual assault and sentenced to a term of twenty-four years. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit obvious error in denying Defendant’s access to immigration records pertaining to the victim’s mother; (2) the process used by the trial court to ensure that Defendant, who spoke Spanish, received adequate interpretation services at trial was appropriate and was not in error; and (3) the remainder of Defendant’s arguments on appeal were without merit.View "State v. Marroquin-Aldana" on Justia Law

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After a jury trial, Defendant was found guilty of murder and sentenced to forty-five years’ imprisonment. The Supreme Court affirmed the judgment and sentence, holding that the trial court did not err in (1) denying Defendant’s motion to suppress the evidence resulting from three searches of his residence by law enforcement officers; (2) allowing a prospective juror to serve on the jury after she disclosed during voir dire that she was once a victim of domestic violence; (3) denying Defendant’s motion to exclude certain physical evidence and failing to exclude expert and nonexpert testimony concerning the significance of that evidence; and (4) imposing a final sentence of forty-five years' imprisonment.View "State v. Diana" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of gross sexual assault, unlawful sexual contact, and furnishing liquor to a minor. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial court did not abuse its discretion in denying Appellant’s motion in limine and motion to continue, both filed on the eve of trial; (2) the trial court did not err in allowing the State to participate in a pretrial hearing on those motions, as the State’s presence did not result in a premature disclosure of Appellant’s trial strategy; and (2) the evidence was sufficient to support the convictions.View "State v. Dube" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of aggravated attempted murder, arson, and burglary. The sentencing court sentenced Defendant to fifty years imprisonment for the aggravated attempted murder. The Supreme Court affirmed the convictions and the sentence, holding (1) the trial court did not abuse its discretion in admitting evidence that Defendant attempted to put another person’s spit into his mouth before submitting to a cheek swab for a DNA sample, and the State did not engage in prosecutorial misconduct; and (2) the sentencing court did not abuse its discretion in sentencing Defendant, and a comparison of the gravity of the offense and the severity of Defendant’s sentence did not result in an inference of gross disproportionality.View "State v. Freeman" on Justia Law

Posted in: Criminal Law