Justia Maine Supreme Court Opinion Summaries

Defendant Philip Galarneau, III appealed his conviction as a âhabitual offenderâ for âoperating while under the influence.â In 2008, without a lawyer, Defendant pled not guilty to the charges in the district court. On the same day, an information containing the same charges was filed in the Superior Court where the State sought to revoke Defendantâs probation from a 2007 assault conviction. The district court charges were dismissed, and Defendant made his appearance at the probation revocation hearing at Superior Court. Defendant was appointed a lawyer-for-the-day. Defendantâs case was called, the court read the charges against him and asked both Defendant and his attorney whether he was advised of his rights. The court confirmed on record that Defendant waived his right to a trial, that he was pleading guilty to habitual offender and OUI charges, and that he admitted violating his probation. The Court sentenced Defendant to approximately two years for all the charges against him. On appeal to the Supreme Court, Defendant argued that his sentence and conviction were unconstitutionally imposed because the court did not inform Defendant of his right to counsel at the district court. The Supreme Court rejected that argument, finding that Defendant was represented by a lawyer-for-the-day during his initial appearance at Superior Court, and that the court confirmed Defendant was advised of his rights. The Court affirmed Defendantâs conviction and sentence.

In October, 2002, a trial court entered a judgment on a jury verdict finding Defendant Jeffrey Cookson guilty on two counts of intentional murder for the deaths of his ex-girlfriend and her best friend. The court sentenced Defendant to two consecutive life sentences. During the trial, witness David Vantol confessed privately to Defendantâs attorney and a private investigator that he had committed both murders. Immediately after the jury returned its verdict against Defendant, defense counsel disclosed the confession to the court and prosecutor. Later that day, Vantol lead police to a spot in the woods where he had buried miscellaneous articles of clothing, and a gun that testing would reveal was the murder weapon. Vantol continued to confess to the murders, but police did not believe him. They asked him to take a polygraph test, but he failed it. Frantic that no one believed him, Vantol threatened to harm himself. Later he would be admitted to the hospital. While there, Vantol recanted his confessions, and told investigators the items he provided were unrelated to murders. The State kept the items in its possession. Defendant filed motions with the court to have DNA testing done on the clothing and other items still in the Stateâs possession. The Superior Court denied Defendantâs motion regarding the clothing testing, but only gave an analysis of the applicable statute that was the basis of its denial. The court ultimately concluded that Defendant failed to meet the chain-of-custody requirement of the statute. The court did not engage in any analysis or provide any other reasoning for its decision. The Supreme Court vacated the Superior Courtâs decision and remanded the case back to the court so that it may issue findings on all points raised by Defendantâs post-conviction DNA motion.