Justia Maine Supreme Court Opinion Summaries

Defendant appealed from a judgment of conviction entered in the trial court finding him guilty of four counts of criminal threatening with a dangerous weapon, eleven counts of criminal restraint with a dangerous weapon, twenty-two counts of kidnapping, one count of burglary, and one count of criminal restraint. The Supreme Court affirmed, holding (1) Defendant was not denied his right to speedy trial; (2) Defendant was not denied his right to self-representation; (3) the jury instructions accurately and fairly informed the jury in all necessary aspects of the law; (4) the court did not err by not dismissing the kidnapping charge; (5) there was sufficient evidence for the jury to find Defendant held the kidnapping victims for a "substantial period of time"; and (6) the court properly imposed consecutive sentences. View "State v. Hofland" on Justia Law

Defendant appealed from a judgment of conviction entered by the trial court following his conditional guilty plea to manslaughter. Defendant contended (1) the trial court erred in denying his motion to suppress statements he made to police officers during the investigation of his infant daughter's death, and (2) the juvenile court erred by admitting hearsay evidence during Defendant's juvenile bind-over hearing. The Supreme Court affirmed the judgment, holding (1) any statements made by Defendant during interrogations were not subject to the requirements of Miranda and were therefore not excludable on those grounds, the court properly considered Defendant's juvenile status, and the court did not err in concluding that Defendant's confession was voluntary; and (2) the court did not err by treating the hearsay testimony during the bind-over hearing as reliable, and therefore, its admission was not error. View "State v. Jones" on Justia Law

A jury convicted Defendant of unlawful sexual contact and of violating a condition of release. Defendant challenged his convictions on appeal, asserting (1) the superior court erred in denying his request to instruct the jury on assault as a lesser-included offense of unlawful sexual contact, and (2) there was insufficient evidence to find that he had "contact" with the victim in violation of his conditions of release. The Supreme Court (1) vacated the judgment of conviction for unlawful sexual contact, holding that the court failed to properly instruct the jury on assault as a lesser-included offense of unlawful sexual contact; and (2) affirmed the judgment of conviction for violating a condition of release, holding that there was sufficient evidence in the record upon which the jury could find every element of the offense of violating a condition of release beyond a reasonable doubt. View "State v. Gantnier" on Justia Law

After a jury trial, Appellant was convicted of gross sexual assault and two counts of aggravated assault. On appeal Appellant challenged the trial court's failure to sanction the State for what he asserted was a discovery violation and the court's exclusion of his computer expert from testifying at trial. The Supreme Court affirmed, holding (1) the court acted well within its discretion in denying Appellant's motion for sanctions; and (2) the court did not exceed its discretion in excluding Appellant's computer expert, given that the delay in supply the expert report to the State was due to Appellant's own failure to pay his expert, the information supplied to the State days before the trial was not complete, and the substantial deference afforded the trial court in determining the admissibility of expert testimony. View "State v. Silva" on Justia Law

Following a jury trial, Appellant was convicted of manslaughter, aggravated criminal operating under the influence, aggravated leaving the scene of a motor vehicle accident, and operating under the influence. The Supreme Court affirmed, holding (1) the evidence produced at trial permitted a rational jury to find Appellant guilty beyond a reasonable doubt on each of the counts in the indictment; and (2) the court did not err in failing to presume prejudice after an attempted jury tampering, failing to issue a curative instruction after an improper comment by the State, and prohibiting Appellant from impeaching a witness with an audio recording of prior inconsistent statements. View "State v. Cheney" on Justia Law

Paul Clark obtained a temporary protection from abuse order on behalf of his thirteen-year-old son against Defendant Michelle Fundalewicz, the child’s mother and Paul’s ex-girlfriend. At the time, the child resided with Paul and Paul’s then-fiancée (now wife), Miranda Clark. The child received a phone call on the home’s landline while Paul or both Paul and Miranda were not home. The child eventually revealed that Defendant had called him earlier that day. Paul reported the incident to the police. The child provided a written statement to the police stating that Defendant did call and speak with him. The State charged Defendant with violation of a protection order; Defendant pled not guilty to the charge and the matter proceeded to a jury-waived trial. At trial, the child testified that it was instead his cousin who called him. He testified that he said it was Defendant in his written statement to police because Paul had told him that if he did not name Defendant, the child would have to move back in with his mother where he would "get treated like crap" as he had been when he lived with her in the past. Miranda testified that a few days after the incident, she spoke with Defendant on the phone, and Defendant admitted to having called and spoken with the child. At the close of the trial, Defendant orally moved for a judgment of acquittal on the grounds that "the State failed to establish a corpus for the offense charged" because the State did not provide "evidence independent of any potentially incriminating statements that [Fundalewicz] . . . made." The court denied the motion, found Defendant guilty of violating the protection order, and sentenced her to pay a $400 fine. Although largely circumstantial, the Supreme Court concluded that the evidence presented at trial, along with the reasonable inferences that could have been drawn from it, adequately supported the corpus delicti requirement, as well as the court’s finding that Defendant did in fact call her son in violation of the protection order. View "Maine v. Fundalewicz" on Justia Law

Daniel Whitney appealed his conviction on one count of operating under the influence following his conditional guilty plea. Whitney argued on appeal that the trial court erred in issuing an order denying his motion to suppress evidence derived from a police officer's stop of his vehicle. Because the Supreme Court concluded that the stop was unconstitutional, it vacated the judgment and the order denying the motion to suppress. View "Maine v. Whitney" on Justia Law

Defendant Tammy Bragg appealed her conviction for operating under the influence following a jury trial. On appeal, Defendant contended that the court erred when it refused to suppress statements she made at the scene of the accident and at the police station. After review of the trial court record, the Supreme Court affirmed the judgment. View "Maine v. Bragg" on Justia Law

Defendant Aaron J. Patton appealed his conviction following a jury trial at which he was found guilty of four counts of gross sexual assault; one count of unlawful sexual contact; and two counts of sexual abuse of a minor. Upon review, Defendant contended that the court erred in several respects, including: (1) a constitutional error resulting from the court's decision to permit a State's witness (a police officer) to testify over his objection about Defendant's assertion of his right to remain silent shortly before his arrest; (2) the admission of evidence of Defendant's use of hypnosis; (3) the admission of police officer testimony that contained inadmissible hearsay evidence and was unfairly prejudicial; and (4) the misstatement of jury instructions. Upon review of the superior court record, the Supreme Court disagreed and affirmed the judgment. View "Maine v. Patton" on Justia Law

William Weber, Jr. appealed a protection from abuse order entered in district court on a complaint filed by Maureen O'Brien on behalf of her sixteen year old daughter. Weber contended that the court lacked authority to enter a new protection order based solely on the same act of abuse that was the subject of an expired, unextended protection order between the same parties. Upon review, the Supreme Court agreed and vacated the judgment. View "O'Brien v. Weber" on Justia Law