Justia Maine Supreme Court Opinion Summaries

Defendant was convicted for aggravated trafficking in scheduled drugs. The superior court denied Defendant's motion for a new trial. Defendant appealed, arguing that he was entitled to a new trial because he was denied effective assistance of counsel when his attorney failed to advise him of the immigration consequences of his guilty plea. The Supreme Court affirmed, holding (1) the trial court properly denied Defendant's motion for a new trial because post-conviction review was the exclusive avenue for judicial review of an ineffective assistance of counsel claim; and (2) because Defendant did not avail himself of the post-conviction review process, the Court could not decide if, in light of the Supreme Court's decision in Padilla v. Kentucky, the post-conviction review procedure was unconstitutional as applied to Defendant's circumstances. View "State v. Ali" on Justia Law

After a jury trial, Appellant Scott Brockelbank was convicted of aggravated criminal trespass and assault. The Court of Appeals affirmed Appellant's judgment and sentence, holding (1) the evidence was sufficient to disprove Appellant's competing harms defense because there was sufficient evidence for the jury to find that the State disproved at least one of the elements of the defense; and (2) the sentencing court acted within its discretion by permitting the State to introduce information related to Appellant's nonpublic juvenile adjudication during the sentencing proceedings to the limited extent reasonably necessary to respond to and explain information introduced by Appellant related to the same adjudication. View "State v. Brockelbank" on Justia Law

After a jury trial, Luis Pabon was convicted of elevated aggravated assault and attempted murder for the stabbing of his girlfriend and housemate at the time. Pabon's defense was partially built around the claim that he was so intoxicated that he had stabbed the victim in self-defense. On appeal, Pabon contended that the trial court erred by failing to include a dwelling-place exception to the duty to retreat in its self-defense instruction to the jury. The Supreme Court affirmed the judgment of conviction, holding that the court's omission of the dwelling-place exception from its self-defense instruction was not obvious error. View "State v. Pabon" on Justia Law

Defendant Ryan Preston was found guilty of criminal threatening with a dangerous weapon. On appeal, Preston argued (1) that the statutory provisions defining deadly force and discussing defense of premises were unconstitutionally vague, and (2) the trial court did not adequately instruct the jury on the charge of criminal threatening with a dangerous weapon. The Supreme Court affirmed the judgment of the trial court, holding (1) the definition of deadly force was not unconstitutionally vague as it interacted with the definition of defense of premises in this case, and (2) the trial court's jury instructions did not constitute obvious error. View "State v. Preston" on Justia Law

Defendant Malcolm LaVallee-Davidson killed a man by putting a gun to his head and pulling the trigger during consensual sexual activity. At trial, Defendant argued that he did not know that the gun was loaded. The trial court convicted him of manslaughter. On appeal, Defendant argued that the trial court committed obvious error in its jury instructions and that the evidence was insufficient for a jury to find beyond a reasonable doubt that Defendant caused the death of the victim either recklessly or with criminal negligence. The Supreme Court affirmed the judgment, holding (1) the court's jury instructions correctly explained the mistake-of-fact statute and contained neither error nor obvious error, and (2) there was sufficient evidence for the jury to conclude beyond a reasonable doubt that Defendant caused the death of the victim and acted either recklessly or with criminal negligence. View "State v. LaVallee-Davidson" on Justia Law

Benjamin Cook pleaded guilty to gross sexual assault and unlawful sexual contact. The superior court imposed an aggregate sentence of twelve years' imprisonment followed by thirty years of supervised release pursuant to Me. Rev. Stat. 17-A, 1231. Cook appealed, contending that the court abused its discretion (1) in determining a maximum and final sentence pursuant to the sentencing analysis required by Me. Rev. Stat. 71-A, 1252, and (2) in imposing a thirty-year term of supervised release because its separate analysis concerning that component of the sentence was insufficient. On appeal, the Supreme Court announced for the first time the analysis a sentencing court is required to undertake before imposing a term of supervised release pursuant to section 1231. In this case, because the superior court did not have the benefit of the full analysis announced and only briefly articulated the case-specific factors leading it to impose a thirty-year term of supervised release, the Court vacated the term of supervised release and remanded for resentencing. The Court affirmed the sentences in all other respects. View "State v. Cook" on Justia Law

Timothy Burns was convicted of theft of unauthorized taking, a Class C offense, following a jury trial. The Supreme Court affirmed the conviction and sentence, holding (1) because the jury could not have rationally found from the evidence that Burns was guilty of theft of property with a value of less than $1000 and because a theft by unauthorized taking is a Class C offense when the property stolen is valued between $1000 and $10,000, the court's failure to instruct the jury concerning the amount necessary to elevate a theft to a Class C offense was harmless; (2) the evidence was sufficient to establish Burns' guilt beyond a reasonable doubt because the jury rationally could have found from the evidence presented at trial that Burns was guilty of the theft of the check involved in this case, and the jury could only have found that the amount stolen was the amount of the check; and (3) the superior court did not err by sentencing Burns to twenty-two months' incarceration. View "State v. Burns" on Justia Law

Paul Davis was struck and seriously injured by a truck driven by Edwin Rodriguez. Rodriguez was driving while intoxicated soon after he and Davis exited a chartered bus at the conclusion of a business promotion trip. Rodriguez later pleaded guilty to reckless endangerment, aggravated assault, and DUI. Davis filed claims against the business that organized the trip, its employee, the chartered bus company, and its employee (Defendants) for common law negligence. The superior court granted summary judgment in favor of Defendants. At issue on appeal was whether Defendants owed Davis a common law duty of care. The Supreme Court affirmed the judgment of the superior court, holding (1) the chartered bus company and the employee who drove the bus did not owe Davis a duty to ensure his safety by preventing Rodriguez from driving his truck after the bus trip ended, and (2) the business that organized the trip and its employee did not have a fiduciary duty to Davis because the employee organized and led the excursion. View "Davis v. Dionne" on Justia Law

Eli Blackhouse filed a complaint for protection from abuse against Jane Doe, alleging he was a victim of Doe's stalking and asserting that Doe's actions contributed to the deterioration of his health. Blackhouse sought an order prohibiting Doe from having any contact with him or minor children in his charge and from being at or in the vicinity of his residence, school, business, or place of employment without cause. With his complaint, Blackhouse submitted a request for reasonable accommodation, stating he was disabled and unable to be physically present in court. The district court denied Blackhouse's request for an ex parte temporary order of protection from abuse and dismissed his complaint after Blackhouse failed to appear for the final hearing. There was no indication that Blackhouse's request for reasonable accommodation was called to the court's attention or that the court otherwise reviewed it before dismissing the complaint. On appeal, the Supreme Court vacated the dismissal, holding that the district court erred by dismissing Blackhouse's complaint without first considering his request for reasonable accommodation of his claimed disability. Remanded. View "Blackhouse v. Jane Doe" on Justia Law

Following a jury-waived trial, Daniel Milne was convicted of eluding an officer, passing a roadblock, operating a vehicle after suspension, and driving to endanger. Milne appealed, contending that the evidence was insufficient to support the court's finding him guilty, beyond a reasonable doubt, of the charges of eluding an officer and passing a roadblock. The Supreme Court (1) affirmed Milne's conviction for eluding an officer, and (2) vacated Milne's conviction for passing a roadblock, holding that the available evidence in the record was insufficient to support a finding, beyond a reasonable doubt, that Milne committed the offense where there was no clearly identifiable police roadblock requiring vehicles to stop. Remanded for reconsideration of sentence. View "State v. Milne" on Justia Law