Justia Maine Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of unlawful sexual contact, unlawful sexual touching, and two counts of assault. The Supreme Court affirmed, holding (1) the trial court did not err in limiting Defendant’s cross-examination of the victims’ mother regarding sexual abuse that the mother experienced as a child; (2) the trial court did not abuse its discretion in denying Defendant’s motion for a mistrial after a fragment of a police interview that the parties had agreed to redact was mistakenly played for the jury; (3) the trial court did not commit obvious error in failing to excuse or inquire further of a juror who worked for the same company as Defendant after finding that the juror and Defendant did not recognize each other; and (4) there was sufficient evidence to support the jury’s verdict. View "State v. Logan" on Justia Law

Defendant’s probation officer asked Defendant to come to the probation office. When Defendant complied, he met two state troopers who sat down with him and asked him about a theft at the victim’s apartment. After the interview, Defendant made incriminating statements. Defendant was charged with burglary and theft by unauthorized taking or transfer. Defendant moved to suppress the statements he made to law enforcement. The trial court determined that Defendant spoke voluntarily and that he was not in custody, and therefore, Miranda warnings were not required. Defendant was subsequently convicted of theft by unauthorized taking or transfer. The Supreme Court affirmed, holding (1) the trial court did not err in determining that Miranda warnings were unnecessary because Defendant was not in custody; (2) the trial court did not err in concluding that the confession was voluntary; and (3) the evidence was sufficient to support the conviction. View "State v. Kittredge" on Justia Law

Glen Harrington pleaded guilty in 2012 to eluding an officer and admitted to violating the conditions of his probation. Harrington was sentenced to forty-eight months’ imprisonment. The Department of Corrections subsequently determined that Harrington was eligible to receive seven days per month of good-time credits and that Harrington would be eligible to receive an additional two days per month for participation in transition-plan programs. Harrington appealed this determination, arguing that he was entitled, for the entire duration of his sentence, to the two days per month for participation in transition-plan programs. The post-conviction court summarily dismissed the petition on the basis that calculations of good time credits are not reviewable in post-conviction proceedings. Harrington appealed, arguing that his petition did not challenge a “calculation” of the credits but instead challenged the Department’s policy of making the credit available to only to inmates at a certain point in their sentences. The Supreme Court affirmed, holding that the post-conviction court did not err in construing the Department’s decision as a calculation of good-time credits and dismissing Harrington’s petition. View "Harrington v. State" on Justia Law

After a jury trial, Appellant was found guilty of elevated aggravated assault, burglary, and violation of a condition of release. The Supreme Court affirmed, holding that the trial court did not err in (1) admitting into evidence a witness’s videotaped interview with police; (2) excluding evidence of an alternative suspect; (3) imposing a significant sanction on the State for a discovery violation; (4) declining to instruct the jury that it could infer that evidence destroyed by the State was favorable to Appellant; and (5) declining to allow Appellant to play a 911 tape during his initial cross-examination of a police detective. Further, the State’s destruction of the victim’s clothing and failure to produce certain witness statements in discovery did not violate Defendant’s right to due process or deprive him of a fair trial. View "State v. Cruthirds" on Justia Law

After a jury-waived trial, Defendant was convicted of failing to provide his correct, name, address, and date of birth; possession or distribution of dangerous knives; and refusing to submit to arrest or detention. The Supreme Court vacated Defendant’s conviction of failing to give his correct name, address, and date of birth but otherwise affirmed, holding (1) the trial court did not violate Defendant’s Confrontation Clause rights at a suppression hearing by admitting testimony of police officers because the testimony was not hearsay; and (2) the evidence presented at trial was insufficient to sustain Defendant’s conviction of failing to give his correct name, address, and date of birth. View "State v. Johnson" on Justia Law

After a hearing, the superior court determined that Dan Brown, a farmer in Blue Hill, unlawfully sold milk without a milk distributor’s license, sold unpasteurized milk in containers that were not labeled “not pasteurized,” and operated a food establishment without a license. The Supreme Court affirmed, holding (1) the superior court did not err in concluding that equitable estoppel did not bar the State from enforcing its licensing requirements for raw milk distributors; (2) the Blue Hill ordinance exempting local food producers and processors from municipal licensing and inspection requirements did not exempt Brown from the State’s licensing requirements; and (3) Brown did not substantially comply with raw milk labeling requirements by posting a small sign at his farm stand. View "State v. Brown" on Justia Law

The State seized twenty-six cats in Defendant’s home and spent $36,800 to treat, house, and care for the cats. Defendant was ultimately convicted of cruelty to animals. Defendant was prohibited from owning any animals except two spayed or neutered cats and required to pay $18,000 in restitution to the State. The Supreme Court affirmed the district court’s judgment, holding (1) the district court did not abuse its discretion in quashing a subpoena that would have compelled one of Defendant’s witnesses to testify; (2) Maine’s cruelty-to-animals statute is not unconstitutionally vague; and (3) there was sufficient evidence to sustain a finding of cruelty to animals and to support the district court’s restitution order. View "State v. Peck" on Justia Law

After a jury trial, Defendant was found guilty of one count each of arson, burglary, aggravated criminal mischief, and theft. Defendant subsequently filed a motion for a judgment of acquittal as to the arson conviction. After a hearing, the trial court granted the motion and acquitted Defendant of the arson charge. The State appealed, arguing that there was sufficient evidence upon which a jury could have concluded that Defendant committed arson, either directly or as an accomplice. The Supreme Court vacated the judgment of acquittal, holding that the trial court erred in entering the judgment of acquittal, as there was sufficient evidence from which the jury could have concluded beyond a reasonable doubt that Defendant was an accomplice to arson. View "State v. Chapman" on Justia Law

In 2013, Defendant was tried on a charge of domestic violence assault. During the trial proceedings, the trial court granted Defendant’s motion for a mistrial after finding manifest necessity to declare a mistrial. Concluding that the mistrial did not involve prosecutorial misconduct, the trial court ruled that the State was entitled to retry its case. Defendant appealed, arguing that double jeopardy barred retrial. The Supreme Court affirmed, holding that because Defendant consented to a mistrial, and because intentional prosecutorial misconduct did not bar a retrial, there was no barrier to retrial under the double jeopardy clause. View "State v. Johnson" on Justia Law

After a jury trial, Appellant was convicted of assault on an officer and criminal mischief. Appellant appealed, arguing that his trial counsel provided ineffective assistance by electing not to make an opening statement, not cross-examining the State’s witnesses, not presenting any evidence for the defense, and presenting only a brief closing argument. The Supreme Court affirmed, holding that the issues Appellant raised regarding ineffective assistance of counsel were not properly raised on direct appeal and instead must be addressed in a fact-finding proceeding to determine if trial counsel’s action resulted from incompetence, appropriate strategic choices, or other considerations. View "State v. Troy" on Justia Law