Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction for operating under the influence, holding that the trial court did not err in concluding that Defendant’s defense that his operation of a motor vehicle was involuntary did not apply to the facts of this case. Specifically, the Court held (1) the trial court erred in concluding that the involuntariness defense can never apply to strict liability crimes; but (2) the court did not err to the extent that it concluded that the defense of voluntariness did not apply to the facts of the matter before it. During trial, Defendant argued that his conduct was directed by “command hallucinations,” and therefore, the involuntary conduct defense applied in this case. View "State v. Griffin" on Justia Law

In this defamation case, the Supreme Judicial Court affirmed the superior court’s dismissal of Marie Gunning’s complaint without prejudice for failure to effect service on the defendants, holding that Gunning was estopped from a prior California judgment from continuing to seek the Does’ identities. Marie Gunning brought suit against the anonymous publisher and writer (collectively, John Doe) of News as Viewed from a Crow’s Nest (Crow's Nest), a publication distributed locally in Freeport, Maine and accessible on the Internet, claiming that Crow’s Nest published defamatory statements about her in several of its issues. During the proceedings, a California court quashed a subpoena that Gunning served on the Crow’s Nest website host seeking to identify Doe. Thereafter, the superior court dismissed Gunning’s complaint without prejudice for failure to effect service on the defendants. The Supreme Judicial Court affirmed, holding that because the issue decided by the California court in a final judgment was the same issue that Gunning sought to have a Maine court revisit, and because Gunning had the opportunity and incentive to litigate that issue in California, she was estopped from relitigating it in the Maine action. View "Gunning v. Doe" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2), holding that the evidence was sufficient to support the judgment. Specifically, the district court did not err in finding, by clear and convincing evidence, at least one ground of parental unfitness and that termination of parental rights was in the best interest of the child. The child, now almost three and a half years old, was born drug affected. Mother was addicted to prescription drugs and failed to make significant progress in reunifying with the child over the past two years. View "In re River B." on Justia Law

Defendant appealed his conviction of operating under the influence (OUI) with a refusal to submit to a chemical test and of operating after suspension (OAS), arguing (1) the State failed to lay a proper foundation for the admission of testimony regarding horizontal gaze nystagmus (HGN) tests performed on Defendant after he was stopped for a traffic violation; and (2) the court committed obvious error by considering testimony from the OUI portion of the trial - as presented to the jury - to conclude that the State proved the operation element of the OAS charge - which was decided by the court. The Supreme Judicial Court affirmed, holding (1) the State laid a proper foundation for the admission of testimony regarding the HGN tests pursuant to State v. Taylor; and (2) where the trial court did not formally sever the OAS and OUI charges and, rather, the parties agreed before trial to have the court decide the OAS charge for “strategic reasons,” the court did not commit obvious error when it considered testimony presented to the jury on the OUI charge in deciding the OAS charge. View "State v. Hinkel" on Justia Law

Defendant was convicted of domestic violence assault, domestic violence stalking, and endangering the welfare of a child. The Supreme Judicial Court vacated the judgment of conviction as to the charge of domestic violence assault and remanded for entry of a judgment of acquittal on that charge, holding that the record contained insufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant’s conduct forming that basis for domestic violence assault occurred within the relevant limitations period. The Court also remanded to determine whether resentencing was necessary as to the stalking and endangering the welfare of a child charges. View "State v. Lacourse" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated assault, two counts of domestic violence assault, and related offenses. Defendant appealed, arguing, inter alia, that the court erred in denying his motion to suppress statements he made to a police officer prior to his arrest. Defendant also appealed his sentence. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that Defendant was not in custody for Miranda purposes and consequently denying his motion to suppress; (2) the court did not abuse its discretion in admitting the testimony of an expert witness who testified about the causes, effects, and symptoms of strangulation; and (3) the court did not abuse its discretion in sentencing Defendant. View "State v. Perry" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder. The Supreme Judicial Court affirmed the judgment, holding (1) the motion court did not err in denying Defendant’s motion to suppress statements he made to law enforcement officers prior to 12:44 p.m. on July 18, 2013 because Defendant was not in custody for Miranda purposes that morning; (2) the motion court did not err in concluding that the Miranda violation occurring after 12:44 p.m. on July 18 did not mandate suppression of statements made on July 23 and 24; (3) the State’s attorney did not commit prosecutorial misconduct during opening statement and closing argument; and (4) the State presented sufficient evidence to support the murder conviction. View "State v. Cote" on Justia Law

After Henry B. was admitted to Pen Bay Medical Center (PBMC), PBMC staff applied to involuntarily commit Henry pursuant to the “white paper” procedures of Me. Rev. Stat. 34-B, 3863(5-A). After a commitment hearing, the district court ordered that Henry be submit to involuntary hospitalization for up to 120 days. The superior court affirmed the district court’s judgment of involuntary commitment. Henry appealed, arguing that he was not provided with effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) individuals subject to involuntary commitment proceedings in Maine have the right to effective representation of counsel, and the Strickland standard applies for courts reviewing claims of ineffective assistance of counsel in involuntary commitment proceedings; and (2) Henry was not deprived of the effective assistance of counsel in this case. View "In re Henry B." on Justia Law

After a jury trial, Defendant was found guilty of domestic violence assault and obstructing the report of a crime or injury. The court sentenced Defendant to three years’ incarceration with all but nine months suspended and three years’ probation, plus fees. The Supreme Judicial Court affirmed, holding (1) the trial court did not commit prejudicial error by not sua sponte declaring a mistrial when the prosecutor commented on Defendant’s right not to testify during the State’s rebuttal closing argument; and (2) the trial court did not err by denying Defendant’s motions for a mistrial after the jury heard statements by the victim regarding Defendant’s prior interactions with police and the victim’s consultation with a domestic violence program and acquisition of a protection order. View "State v. Tarbox" on Justia Law

In 2014, Joyce Mitchell filed a complaint for divorce from Alexander Krieckhaus. In 2016, the parties reached a settlement agreement. A stipulated order on children’s issues was signed by the court on that date. The court later entered a divorce judgment in which it based the amount of child support upon the parties providing substantially equal care for their son. Mitchell subsequently filed a motion for findings of fact and conclusions of law, reconsideration of the child support order, and deviation from the child support guidelines, arguing, inter alia, that before the court issued a child support order it was required to hold an evidentiary hearing on the issue of whether the parties provided substantially equal care of their son. The court issued an order denying all of Mitchell’s motions. The Supreme Court vacated the judgment of divorce insofar as it established a child support obligation to be paid by Mitchell and remanded for an evidentiary hearing on that issue, holding that the court erred in finding that the parties had agreed to a substantially equal care arrangement with regard to their son without providing the parties with a meaningful opportunity to present evidence on this issue. View "Mitchell v. Krieckhaus" on Justia Law