Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was found guilty of one count each of arson, burglary, aggravated criminal mischief, and theft. Defendant subsequently filed a motion for a judgment of acquittal as to the arson conviction. After a hearing, the trial court granted the motion and acquitted Defendant of the arson charge. The State appealed, arguing that there was sufficient evidence upon which a jury could have concluded that Defendant committed arson, either directly or as an accomplice. The Supreme Court vacated the judgment of acquittal, holding that the trial court erred in entering the judgment of acquittal, as there was sufficient evidence from which the jury could have concluded beyond a reasonable doubt that Defendant was an accomplice to arson. View "State v. Chapman" on Justia Law

In 2013, Defendant was tried on a charge of domestic violence assault. During the trial proceedings, the trial court granted Defendant’s motion for a mistrial after finding manifest necessity to declare a mistrial. Concluding that the mistrial did not involve prosecutorial misconduct, the trial court ruled that the State was entitled to retry its case. Defendant appealed, arguing that double jeopardy barred retrial. The Supreme Court affirmed, holding that because Defendant consented to a mistrial, and because intentional prosecutorial misconduct did not bar a retrial, there was no barrier to retrial under the double jeopardy clause. View "State v. Johnson" on Justia Law

After a jury trial, Appellant was convicted of assault on an officer and criminal mischief. Appellant appealed, arguing that his trial counsel provided ineffective assistance by electing not to make an opening statement, not cross-examining the State’s witnesses, not presenting any evidence for the defense, and presenting only a brief closing argument. The Supreme Court affirmed, holding that the issues Appellant raised regarding ineffective assistance of counsel were not properly raised on direct appeal and instead must be addressed in a fact-finding proceeding to determine if trial counsel’s action resulted from incompetence, appropriate strategic choices, or other considerations. View "State v. Troy" on Justia Law

In 2011, the State charged Defendant of aggravated assault and attempted murder. The State alleged that while Defendant and his wife, Lisa, were hiking on Megunticook Mountain, Defendant struck Lisa in the head, dragged her to the edge of a cliff, and threw her over the edge. Shortly thereafter, Defendant was seriously injured after himself falling from a cliff. Defendant was treated at Eastern Maine Medical Center for several days. In 2012, the State obtained a search warrant to obtain Defendant’s personal medical records from the hospital. Defendant filed a motion to suppress his medical records or, in the alternative, to dismiss the charges against him, contending that the State failed to use the proper procedure in obtaining his records, the search warrant was overbroad and not supported by probable cause, and the use of the search warrant during his criminal proceeding violated his due process rights. The trial court declined to suppress Defendant’s medical records. The Supreme Court dismissed Defendant’s appeal as interlocutory, holding that the trial court’s decision not to suppress the evidence did not give rise to a right to an interlocutory appeal. View "State v. Black" on Justia Law

After a bench trial, Defendant was convicted of criminal trespass for entering a Rite Aid store six months after a police officer ordered Defendant not to be on the premises. Defendant appealed, arguing that the State failed to prove that he violated the criminal trespass statute because the officer was not “authorized” under the meaning of the statute to order Defendant not to enter the Rite Aid. The Supreme Court affirmed the judgment, holding that the evidence was sufficient for the fact-finder to rationally infer, beyond a reasonable doubt, that the officer was authorized by Rite Aid, and within the meaning of the criminal trespass statute, to order Defendant not to enter the Rite Aid store. View "State v. Sanchez" on Justia Law

After a jury trial, Defendant was convicted of two counts of gross sexual assault and suspended to twenty years imprisonment. On appeal, Defendant argued that the evidence was insufficient to sustain his convictions, that the prosecutor engaged in impermissible misconduct, and the trial court erred in determining his sentence. The Supreme Court vacated the judgments of conviction, holding (1) the prosecutor violated the state and federal Constitutions by eliciting testimony that Defendant did not return phone calls from police and by arguing to the jury that Defendant’s pre-arrest silence demonstrated consciousness of guilt, and the error seriously affected the fairness and integrity of the judicial proceedings; and (2) the prosecutor committed misconduct by vouching for witness credibility even after the court determined that the statements were impermissible, and the error was not harmless. View "State v. Lovejoy" on Justia Law

After a jury trial, Defendant was convicted of one count of gross sexual assault. On appeal, Defendant argued that the trial court committed obvious error by permitting the State to introduce evidence of his pre-arrest refusal to voluntarily submit to a warrantless collection of a DNA sample and to argue to the jury that it could infer consciousness of guilt from the refusal. The Supreme Court vacated the judgment, holding that the trial court committed obvious error in admitting evidence of Defendant’s refusal to submit to the warrantless search for the purpose of proving consciousness of guilt. Remanded. View "State v. Glover" on Justia Law

After a six-day jury trial, Defendant was convicted of gross sexual assault and sentenced to a term of twenty-four years. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit obvious error in denying Defendant’s access to immigration records pertaining to the victim’s mother; (2) the process used by the trial court to ensure that Defendant, who spoke Spanish, received adequate interpretation services at trial was appropriate and was not in error; and (3) the remainder of Defendant’s arguments on appeal were without merit. View "State v. Marroquin-Aldana" on Justia Law

After a jury trial, Defendant was found guilty of murder and sentenced to forty-five years’ imprisonment. The Supreme Court affirmed the judgment and sentence, holding that the trial court did not err in (1) denying Defendant’s motion to suppress the evidence resulting from three searches of his residence by law enforcement officers; (2) allowing a prospective juror to serve on the jury after she disclosed during voir dire that she was once a victim of domestic violence; (3) denying Defendant’s motion to exclude certain physical evidence and failing to exclude expert and nonexpert testimony concerning the significance of that evidence; and (4) imposing a final sentence of forty-five years' imprisonment. View "State v. Diana" on Justia Law

After a jury trial, Appellant was found guilty of gross sexual assault, unlawful sexual contact, and furnishing liquor to a minor. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial court did not abuse its discretion in denying Appellant’s motion in limine and motion to continue, both filed on the eve of trial; (2) the trial court did not err in allowing the State to participate in a pretrial hearing on those motions, as the State’s presence did not result in a premature disclosure of Appellant’s trial strategy; and (2) the evidence was sufficient to support the convictions. View "State v. Dube" on Justia Law