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Me. Rev. Stat. 17-A, 1112 is facially constitutional, and, in the instant case, the trial court’s admission of a lab certificate in lieu of live witness testimony pursuant to that statute was not a violation of Defendant’s right of confrontation. Defendant appealed from a judgment, entered after a jury trial, convicting her of unlawful trafficking of a schedule W drug. At issue was whether the trial court’s admission of a lab certificate identifying a substance exchanged in a controlled purchase as methamphetamine. The court admitted the lab certificate in lieu of the testimony of the chemist pursuant to section 1112. The Supreme Court affirmed, holding (1) section 1112 is facially constitutional; (2) Defendant’s failure to timely demand a live witness pursuant to section 1112 effected a voluntary, knowing, and intentional waiver of her Confrontation Clause rights; and (3) therefore, the trial court did not err in allowing into admission the chemist’s certificate in lieu of live testimony. View "State v. Jones" on Justia Law

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The motion court did not err by applying the inevitable discovery doctrine to deny Defendant's motion to suppress evidence of drugs found on his person before the issuance of a search warrant. The Unified Criminal Docket found Defendant guilty of unlawful trafficking in scheduled drugs and ordering a criminal forfeiture. In denying Defendant’s motion to suppress drug evidence, the trial court found that law enforcement officers’ warrantless entry into an apartment was not justified by exigent circumstances but that it was highly likely that the officers inevitably would have discovered drugs. The Supreme Court affirmed the denial of the motion to suppress, holding (1) the motion court did not err by finding that the police inevitably would have discovered the drug evidence at issue by lawful means; and (2) application of the inevitable discovery doctrine does not create an incentive for police misconduct and does not significantly weaken Fourth Amendment protections. View "State v. Prinkleton" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of possession of sexually explicit material depicting a minor under twelve years old and the sentence imposed in connection with the conviction. The court imposed a sentence of three years’ incarceration and two years of probation with certain conditions, including a restriction against unsupervised contact with children under the age of sixteen years. Defendant appealed, challenging the denial of his motion to suppress his statements to the police and the condition of his probation permitting him only supervised contact with his infant son. The Supreme Court held (1) the admission of Defendant’s confession was fundamentally fair; and (2) the “no unsupervised contact” provision of Defendant’s probation was within the court’s authority and did not violate Defendant’s constitutional rights. View "State v. Annis" on Justia Law

Posted in: Criminal Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii), (iv). On appeal, Father argued that the district court erred by finding that he was unfit as a parent and abused its discretion by determining that termination of his parental rights was in the child’s best interest. The Supreme Judicial Court held (1) the district court’s findings that Father was unfit as a parent had support from competent evidence in the record; and (2) the district court did not abuse its discretion in determining that termination of Father’s parental rights was in the child’s best interest. View "In re James C." on Justia Law

Posted in: Family Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Parents’ parental rights to their child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(ii). On appeal, Parents challenged the sufficiency of the evidence supporting the district court’s finding of parental unfitness and the court’s discretionary determination that termination was in the best interest of the child. In addition, Father argued that the Department did not meet its obligation to provide reunification services. The Supreme Judicial Court held that the district court did not err or abuse its discretion in determining that termination of Parents’ parental rights, with a permanency plan for adoption, was in the child’s best interest. View "In re Emma S." on Justia Law

Posted in: Family Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Mother’s parental rights pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2). On appeal, counsel for Mother filed an appellate brief containing a statement that counsel believed there were no arguable issues of merit for an appeal. The Supreme Judicial Court held (1) the record supported the district court’s findings of parental unfitness as to Mother; and (2) there was sufficient evidence in the record to support the court’s findings and discretionary determination that termination of Mother’s parental rights was in the children’s best interests. View "In re Dante C." on Justia Law

Posted in: Family Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv). On appeal, Father argued that the evidence was insufficient as to the finding of unfitness and challenged the district court’s finding and discretionary determination that termination was in the child’s best interest. The Supreme Judicial Court held (1) the evidence was sufficient to support the court’s unfitness findings; and (2) the evidence was sufficient to support a finding that termination was in the child’s best interest. View "In re Emma C." on Justia Law

Posted in: Family Law

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The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant’s motion for a new trial, which Defendant brought pursuant to the post-conviction DNA analysis statute, Me. Rev. Stat. 15, 2135-2138. The Supreme Judicial Court held that the district court did not err or abuse its discretion by (1) finding that Defendant failed to show by clear and convincing evidence that new DNA evidence admitted at the hearing on Defendant’s motion made it probable that a different verdict would result upon a new trial; and (2) declining to consider evidence pointing to an alternative suspect upon finding that the proffered evidence was not relevant to the new DNA evidence. View "State v. Bates" on Justia Law

Posted in: Criminal Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his two children pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv). On appeal, Father argued that the guardian ad litem failed to satisfy his statutory obligations to conduct an in-person interview with Father and to notify Father’s attorney that Father was imprisoned before the cease reunification order went into effect. The Supreme Judicial Court disagreed, holding (1) Father’s argument regarding the notification of incarceration failed for several reasons; and (2) the court’s findings that Father was unfit and that termination was in the children’s best interests was not in error or an abuse of discretion. View "In re Aurora M." on Justia Law

Posted in: Family Law

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The Supreme Judicial Court affirmed the judgment of the district court, entered after a jury trial, finding that Defendant had committed the civil violations of improperly displaying a registration plate and failing to register a vehicle that is operated or remains on a public way. Contrary to Defendant’s arguments on appeal, the Supreme Court held (1) the district court did not err in finding that the State established the elements of each violation; and (2) the court proceedings below did not violate the Due Process Clause, the Equal Protection Clause, or the Americans with Disabilities Act. View "State v. Chase" on Justia Law