Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed in part and vacated in part the judgment of the trial court convicting Defendant of gross sexual assault and four related crimes, holding that a specific unanimity instruction was necessary as to counts three and four.On appeal, Defendant argued that the trial court erred in not giving a specific unanimity instruction. The State conceded that a specific unanimity instruction was necessary as to counts three and four. The Supreme Court (1) vacated Defendant's convictions as to counts three and four; and (2) affirmed the judgment on but vacated Defendant's sentences imposed on counts one, two, and five because the sentences may have been affected by the now-vacated convictions on counts three and four. View "State v. Russell" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs and one count of unlawful trafficking in scheduled drugs and finding that $1,500 was subject to criminal forfeiture, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) Defendant's claim that his right to a speedy trial was violation under the Maine Constitution failed because he did not adequately assert his right, and his speedy trial claim under the United States Constitution failed under obvious error review; (2) Defendant's claim under the Maine Constitution that evidence obtained pursuant to the execution of a search warrant was inadmissible was unpreserved, and his claim under the United States Constitution that the warrants were not supported by probable cause failed; and (3) Defendant's last argument on appeal was unavailing. View "State v. Norris" on Justia Law

The Supreme Judicial Court affirmed the trial court's judgment of conviction of unlawful sexual contact entered after a jury trial, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the prosecutor did not err in making statements during closing arguments stating that consideration of motive was important; (2) the trial court did not commit obvious error in instructing the jury regarding motive, the State's burden of proof, or the presumption of Appellant's innocence; and (3) the trial court did not commit obvious error in the way it handled the process of allowing the jurors to decide when to proceed with the trial after a potential COVID-19 exposure. View "State v. Warner" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction on charges of domestic violence aggravated assault and domestic violence assault and the trial court's finding of guilty on a charge of violating a condition of release, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the trial court violated his constitutional right to a representative jury by using the absolute disparity test to determine the racial makeup of the jury venire. The Supreme Judicial Court disagreed and affirmed, holding that the trial court (1) appropriately determined the 1.01% absolute disparity in Defendant's jury venire was insufficient to show underrepresentation; and (2) did not abuse its discretion in denying Defendant's motion to subpoena the grand jurors. View "State v. Footman" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of eluding an officer after a jury found him guilty of that offense and two misdemeanors, holding that the evidence rationally supported the jury's verdict.The jury returned a verdict finding Defendant guilty of all three charges for which he was indicted. Defendant moved for judgment of acquittal on the charge of eluding an officer, arguing that his speed was not reckless under the circumstances. The court granted the motion. The Supreme Judicial Court vacated the judgment of acquittal, holding that the jury could rationally find that Defendant operated at a "reckless rate of speed" - a required element of eluding an officer. View "State v. Brackett" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in favor of the City of Sanford following a jury trial on Plaintiff's complaint alleging that the City discriminated against him because of his disability, in violation of the Maine Human Rights Act (MHRA), Me. Rev. Stat. 5, 4553-A(1)(A)(C)-(D), holding that there was no error in the proceedings below.On appeal, Plaintiff argued that the superior court erred in excluding his proposed jury instruction that "it is illegal as a matter of law for any employer to impose a 100% healed or 100% fit policy on any applicants for employment or any employees." The Supreme Court disagreed and affirmed, holding (1) Plaintiff properly preserved his objection to the court's instructions; and (2) the trial court did not err by rejecting Plaintiff's proposed instruction because it was sufficiently covered in the court's instructions. View "Smith v. City of Sanford" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful trafficking in scheduled drugs and falsifying physical evidence, entered after a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized as the result of what Defendant argued was an unlawful arrest; (2) there was no obvious error in the admission of lay opinion testimony by law enforcement officers on certain matters; (3) the record evidence was sufficient to justify the trial court's giving a permissible-inference instruction; and (4) there was no error or abuse of discretion in the denial of Defendant's motion for new trial and for judgment of acquittal. View "State v. Abdullahi" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of burglary, entered following a jury trial, holding that Defendant was not entitled to relief on his argument that he should be granted an acquittal.Defendant was indicted for various offenses, including burglary. During the jury trial, after the State rested, Defendant moved for a judgment of acquittal on the grounds that the State had not proven that he was not licensed or privileged to be in the house at issue because he was legally present on the premises as a tenant. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence in the record from which the jury could find that Defendant knew that he lacked the right to possess or occupy the premises the night of the offense; and (2) therefore, Defendant was not entitled to an acquittal. View "State v. Every" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault but vacated his sentence of eight years' imprisonment to be followed by eight years of supervised release, holding that there was no error in Defendant's conviction but that the sentencing analysis used by the trial court resulted in obvious error that required correction.On appeal, Defendant argued that the trial court committed obvious error in its treatment of a note from the jurors during jury deliberations and because of prosecutorial error. The Supreme Judicial Court remanded the case for resentencing, holding (1) Defendant waived any objection to the court's response to the note; (2) there was no prosecutorial error or impropriety; and (3) the lower court had the authority to impose what was a lawful amended sentence, but the sentencing analysis employed by the court required that this Court vacate the sentence and remand for a de novo sentencing hearing. View "State v. Cummings" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for aggravated assault, robbery, domestic violence assault, domestic violence criminal threatening, and theft by unauthorized taking or transfer but reversed his sentence, holding that the trial court erred by failing to merge duplicative counts.The Supreme Judicial Court remanded this case for resentencing, holding (1) the trial court did not err in failing to give a specific unanimity instruction in addition to the given general unanimity instruction; (2) the trial court erred in failing to merge the duplicative counts of theft by unauthorized taking or transfer and robbery, resulting in a double-jeopardy violation; and (3) the trial court's reliance on Defendant's decision to seek a trial as an aggravating factor in his sentence was unconstitutional. View "State v. Chase" on Justia Law