Justia Maine Supreme Court Opinion Summaries
Articles Posted in Criminal Law
State v. Hayden
After a jury trial, Defendant was found guilty of two counts of knowing or intentional murder and sentenced to two concurrent sentences of life imprisonment. The Supreme Court affirmed the judgment and sentence, holding (1) the evidence presented at trial was sufficient for the jury to find all of the elements of the crime charged; (2) the sentencing court did not misapply sentencing principles; and (3) the sentencing court did not abuse its discretion when it determined that aggravating and mitigating factors did not require a departure from the basic sentence, and the court did not impermissibly or unconstitutionally impose a sentence that was more severe based upon Defendant’s exercise of his right to a trial.View "State v. Hayden" on Justia Law
State v. Mercier
After a jury trial, Defendant was found guilty of intentional or knowing murder and sentenced to seventy years imprisonment. Defendant appealed, arguing, inter alia, that the trial court violated his right to confront witnesses by admitting medical examiner testimony because the testimony relied in part on an autopsy report created by a different medical examiner who did not testify at trial. The Supreme Court affirmed, holding (1) pursuant to State v. Mitchell, the admission of the medical examiner’s testimony was not a violation of the Confrontation Clause; and (2) Defendant’s remaining assertions of error were unavailing.View "State v. Mercier" on Justia Law
State v. Lowden
After a jury trial, Defendant was convicted of aggravated trafficking of scheduled drugs. The Supreme Court vacated the conviction, holding that the trial court erred in denying Defendant’s motion for a judgment of acquittal because the evidence presented at trial was insufficient to support the jury’s guilty verdict. Specifically, the record did not include sufficient evidence from which a jury rationally could conclude, beyond a reasonable doubt, that Defendant successfully manufactured methamphetamine, a necessary element of unlawful trafficking in schedule W drugs. Remanded to the superior court for the entry of a judgment of acquittal.View "State v. Lowden" on Justia Law
Posted in:
Criminal Law
Dee v. State
Since 1983, Michael Dee repeatedly and unsuccessfully challenged in state and federal courts the constitutionality of Maine marijuana prohibitions. In 2007, the superior court enjoined Dee from filing further lawsuits in Maine courts challenging the constitutionality of the State’s marijuana laws. Despite this injunction, Dee did not request the court’s permission to file this complaint for a judgment declaring that provisions in several Maine marijuana statutes were unconstitutional until almost one month after his complaint was docketed. The superior court dismissed Dee’s complaint with prejudice, finding that several Maine courts had already considered and rejected Dee’s arguments and that the suit was frivolous. The Supreme Court affirmed, holding that in light of the frivolous and duplicative nature of the suit and Dee’s failure to seek permission before commencing this action, the superior court did not abuse its discretion in granting the State’s motion to dismiss Dee’s petition with prejudice. View "Dee v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
State v. Gladu
After a jury trial, Defendant was found guilty of several sex offenses. The Supreme Court affirmed after clarifying the conduct the State was required to prove in order to prove the element of penetration, holding that the trial court did not err in (1) denying Defendant’s motion for a judgment of acquittal on the charge of unlawful sexual conduct, as the jury could have rationally made the finding that the State proved beyond a reasonable doubt every element of the offense; and (2) conducting voir dire, as no individual voir dire member disclosed a general bias against a defendant with mental illness.View "State v. Gladu" on Justia Law
Cookson v. State
After a jury trial, Defendant was found guilty of two counts of intentional or knowing murder. After Defendant’s convictions were affirmed on appeal, Defendant filed two consecutive motions seeking post-conviction DNA analysis of certain evidence. The superior court denied the motions, but the Supreme Court remanded for the superior court to make the required findings under the post-conviction DNA statute. On remand, the superior court denied Defendant’s motion a second time. The Supreme Court affirmed, holding that the trial court did not err in finding that Defendant failed to establish the chain of custody necessary to obtain an order for post-conviction DNA analysis.View "Cookson v. State" on Justia Law
Posted in:
Criminal Law
State v. Hill
After a jury trial, Defendant was convicted of criminal operating under the influence and refusing to sign a uniform summons and complaint. On appeal, Defendant argued, among other things, that he did not properly waive his right to be assisted by counsel at trial. The Supreme Court vacated the judgment, holding that the record did not reflect - either through Defendant’s own responses to the court regarding the trial process, counsel’s statements regarding Defendant’s waiver, or evidence regarding whether Defendant was informed about the trial process - that Defendant voluntarily, knowingly, and intelligently waived his constitutional right to counsel.View "State v. Hill" on Justia Law
State v. Norwood
After a jury trial, Defendant was convicted of unlawful trafficking of oxycodone, unlawful possession of oxycodone, and carrying a concealed weapon. The Supreme Court affirmed, holding (1) the trial court did not err in declining to evaluate the basis on which Defendant’s witness asserted his Fifth Amendment privilege against self-incrimination in declining to answer Defendant’s questions; and (2) the district court did not abuse its discretion in admitting evidence of an arrest of two individuals for possession of oxycodone allegedly purchased from Defendant, as the probative value of the evidence did not substantially outweigh the danger of unfair prejudice to Defendant. View "State v. Norwood" on Justia Law
Posted in:
Criminal Law
State v. Stanley
After a jury trial, Defendant was found guilty of operating after habitual offender revocation. Defendant appealed, arguing (1) the trial court erred when it failed to clarify the definition of “public way” as defined in Me. Rev. Stat. 17-A, 505(2); (2) the statute’s language is confusing and unconstitutionally vague; and (3) the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) Defendant failed to preserve her clarification argument; (2) the language of the statute is outdated and confusing but describes a certain type of public way with sufficient certainty to survive a due process challenge; and (3) the evidence was sufficient to support the verdict.View "State v. Stanley" on Justia Law
State v. Bryant
After a jury trial, Defendant was found guilty of manslaughter. Defendant appealed, arguing that the trial court erred in denying his motion to suppress because he was subjected to custodial interrogation and did not receive Miranda warnings and because he was in a state of shock and emotional distress that rendered his statements involuntary. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Defendant’s statements were not made in the course of custodial interrogation for purposes of Miranda; and (2) the trial court did not err in determining that Defendant’s statements were made voluntarily. View "State v. Bryant" on Justia Law