Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Court
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After a jury trial, Defendant was convicted of aggravated attempted murder, arson, and burglary. The sentencing court sentenced Defendant to fifty years imprisonment for the aggravated attempted murder. The Supreme Court affirmed the convictions and the sentence, holding (1) the trial court did not abuse its discretion in admitting evidence that Defendant attempted to put another person’s spit into his mouth before submitting to a cheek swab for a DNA sample, and the State did not engage in prosecutorial misconduct; and (2) the sentencing court did not abuse its discretion in sentencing Defendant, and a comparison of the gravity of the offense and the severity of Defendant’s sentence did not result in an inference of gross disproportionality. View "State v. Freeman" on Justia Law

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After a jury trial, Defendant was found guilty of intentional or knowing murder and sentenced to seventy years imprisonment. Defendant appealed, arguing, inter alia, that the trial court violated his right to confront witnesses by admitting medical examiner testimony because the testimony relied in part on an autopsy report created by a different medical examiner who did not testify at trial. The Supreme Court affirmed, holding (1) pursuant to State v. Mitchell, the admission of the medical examiner’s testimony was not a violation of the Confrontation Clause; and (2) Defendant’s remaining assertions of error were unavailing. View "State v. Mercier" on Justia Law

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After a jury trial, Defendant was convicted of aggravated trafficking of scheduled drugs. The Supreme Court vacated the conviction, holding that the trial court erred in denying Defendant’s motion for a judgment of acquittal because the evidence presented at trial was insufficient to support the jury’s guilty verdict. Specifically, the record did not include sufficient evidence from which a jury rationally could conclude, beyond a reasonable doubt, that Defendant successfully manufactured methamphetamine, a necessary element of unlawful trafficking in schedule W drugs. Remanded to the superior court for the entry of a judgment of acquittal. View "State v. Lowden" on Justia Law

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After a jury trial, Defendant was found guilty of two counts of knowing or intentional murder and sentenced to two concurrent sentences of life imprisonment. The Supreme Court affirmed the judgment and sentence, holding (1) the evidence presented at trial was sufficient for the jury to find all of the elements of the crime charged; (2) the sentencing court did not misapply sentencing principles; and (3) the sentencing court did not abuse its discretion when it determined that aggravating and mitigating factors did not require a departure from the basic sentence, and the court did not impermissibly or unconstitutionally impose a sentence that was more severe based upon Defendant’s exercise of his right to a trial. View "State v. Hayden" on Justia Law

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After a jury trial, Defendant was found guilty of several sex offenses. The Supreme Court affirmed after clarifying the conduct the State was required to prove in order to prove the element of penetration, holding that the trial court did not err in (1) denying Defendant’s motion for a judgment of acquittal on the charge of unlawful sexual conduct, as the jury could have rationally made the finding that the State proved beyond a reasonable doubt every element of the offense; and (2) conducting voir dire, as no individual voir dire member disclosed a general bias against a defendant with mental illness. View "State v. Gladu" on Justia Law

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After a jury trial, Defendant was found guilty of two counts of intentional or knowing murder. After Defendant’s convictions were affirmed on appeal, Defendant filed two consecutive motions seeking post-conviction DNA analysis of certain evidence. The superior court denied the motions, but the Supreme Court remanded for the superior court to make the required findings under the post-conviction DNA statute. On remand, the superior court denied Defendant’s motion a second time. The Supreme Court affirmed, holding that the trial court did not err in finding that Defendant failed to establish the chain of custody necessary to obtain an order for post-conviction DNA analysis. View "Cookson v. State" on Justia Law

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After a jury trial, Defendant was convicted of criminal operating under the influence and refusing to sign a uniform summons and complaint. On appeal, Defendant argued, among other things, that he did not properly waive his right to be assisted by counsel at trial. The Supreme Court vacated the judgment, holding that the record did not reflect - either through Defendant’s own responses to the court regarding the trial process, counsel’s statements regarding Defendant’s waiver, or evidence regarding whether Defendant was informed about the trial process - that Defendant voluntarily, knowingly, and intelligently waived his constitutional right to counsel. View "State v. Hill" on Justia Law

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After a jury trial, Defendant was found guilty of operating after habitual offender revocation. Defendant appealed, arguing (1) the trial court erred when it failed to clarify the definition of “public way” as defined in Me. Rev. Stat. 17-A, 505(2); (2) the statute’s language is confusing and unconstitutionally vague; and (3) the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) Defendant failed to preserve her clarification argument; (2) the language of the statute is outdated and confusing but describes a certain type of public way with sufficient certainty to survive a due process challenge; and (3) the evidence was sufficient to support the verdict. View "State v. Stanley" on Justia Law

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After a jury trial, Appellant was convicted of escape and for assaulting a corrections officer in a courtroom and then fleeing from the courtroom before being captured while attempting to flee from the courthouse. On appeal, Appellant argued, among other things, that the State failed to prove he successfully exited the courthouse after fleeing the courtroom, a finding Appellant claimed was necessary to support his conviction for escape. The Supreme Court affirmed the judgment, holding that the evidence was sufficient to support (1) a finding that Appellant was in custody pursuant to a court order, as was required to support each conviction; and (2) a finding that Appellant left official custody without official permission, which was sufficient to support the escape conviction. View "State v. Troy" on Justia Law

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Mother and Father were married and had a son. After Father was convicted of sexual abuse of girls who had been his piano students, Mother filed for a divorce. The trial court granted the parties a divorce, concluded that Father’s criminal conduct constituted financial misconduct, and divided the parties’ property. The Supreme Court affirmed, holding that the trial court (1) provided findings necessary to support its judgment; (2) did not err as a matter of law in considering Father’s criminal conduct as a relevant factor in arriving at a just division of the parties’ marital estate; and (3) equitably divided the marital property. View "Lesko v. Stanislaw " on Justia Law