Justia Criminal Law Opinion Summaries

Mallory McPartland appealed from a judgment of conviction entered in the criminal docket upon her conditional guilty plea to operating under the influence (OUI) following the denial of her motion to suppress evidence. McPartland argued that the suppression court erred in concluding that the police officer she encountered at an OUI roadblock had a reasonable articulable suspicion of impairment that was sufficient to justify additional sobriety screening. The Supreme Court affirmed the suppression court's finding that the officer had reasonable suspicion to refer McPartland to secondary screening in this case, holding that the court correctly concluded that satisfaction of the reasonable articulable suspicion standard justifies directing a motorist to secondary screening following an initial roadblock stop.

After a jury trial, Kenny Ouellette was convicted of reckless conduct. Ouellette appealed, arguing that the superior court erred in (1) declining to instruct the jury on his justification of self-defense to the charge of reckless conduct, and (2) failing to inform the jury of the parties' out-of-course resolution that resulted in a dismissal of a count of criminal mischief stemming from the same incident. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's instruction to the jury that it could not consider self-defense as to the charge of reckless conduct was erroneous, and (2) the error was not harmless. Remanded for a new trial.

Following a jury trial, Jesse Guyette was convicted of unlawful possession of scheduled drugs. Guyette appealed, arguing that the superior court erred by admitting several statements at trial pursuant to the Me. R. Evid. 804(b)(3) exception to the hearsay rule for statements against penal interest. The Supreme Court vacated Guyette's conviction, holding (1) the trial court abused its discretion by admitting the out-of-court statements of a person who was not a codefendant at trial but whose statements implicated Guyette because the statements did not fall within the Rule 804(b)(3) hearsay exception; and (2) the court's error in admitting those statements was not harmless.

Defendant was indicted for aggravated trafficking of scheduled drugs, unlawful trafficking in scheduled drugs, and illegal importation of scheduled drugs. Defendant moved to suppress incriminating statements he made to a Maine Drug Enforcement Agency (MDEA) agent while in the agent's custody and after Defendant had invoked his right to counsel in violation of the Fifth Amendment. The superior court granted Defendant's motion after applying Maryland v. Shatzer, concluding that the State had failed to prove that Defendant's waiver of his right to counsel was voluntary because the agent had resumed his questioning of Defendant just a few hours after Defendant had invoked his right to counsel, far less than the fourteen-day standard required by Shatzer. The Supreme Court vacated the superior court, holding that the court erred by evaluating the evidence and rendering its findings through the lens of the Shatzer fourteen-day standard and should have employed the analytical framework advanced in Edwards v. Arizona and Oregon v. Bradshaw in determining whether Defendant voluntarily reinitiated interrogation. Remanded for the court to reconsider the evidentiary record and to apply the Edwards and Bradshaw standards.

Following a jury trial, Rory Holland was convicted of two counts of intentional or knowing murder and sentenced to two concurrent life sentences. The Supreme Court affirmed the judgment and sentences, holding (1) the trial court did not abuse its discretion when it refused to admit evidence of the victims' reputations for violence that was not known to Holland prior to the murders; (2) the trial court did not err in admitting a book containing the Maine Criminal Code into evidence where the evidence was not unfairly prejudicial; (3) the trial court properly denied Holland's motion in limine to permit statements from an earlier civil trial to be admitted into evidence to provide context for Holland's reaction to threats and violence; (4) there was sufficient evidence to disprove Holland's claim of self-defense; (5) the trial court did not err by allowing the State to reopen its case to present evidence regarding identification of Holland; and (6) the court did not abuse its discretion in imposing concurrent life sentences.

While Shawn Sayer was incarcerated, the district court granted a final order for protection from abuse to Liv Morrison. Sayer appealed, asserting, inter alia, that he was deprived of due process by not being given the opportunity to be present at or participate in the hearing. The Supreme Court vacated the judgment of the district court, holding that Sayer's incarceration and the need to protect his rights by facilitating his participation in the hearing, either in person or by a remote video or audio connection, demonstrated good cause to either make an accommodation to allow him to participate in the hearing or grant a short continuance of the hearing to allow his participation on another date. Remanded.

After a jury trial, Defendant David Churchill was found guilty of one count of unlawful sexual contact. Defendant appealed, arguing that the trial court erred by admitting in evidence a printout of an online chat between Defendant and the victim, a twelve-year-old girl, because the printout was not authenticated pursuant to Me. R. Evid. 901(a). The Supreme Court affirmed, holding (1) the trial court properly concluded that testimony of a police detective was sufficient to authenticate the chat log, and (2) other evidence established that Defendant was the person with whom the victim was chatting, so no greater showing was required.

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.

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.

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.