Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to operating under the influence. Defendant moved to suppress all evidence obtained from the stop of his vehicle for lack of reasonable articulable suspicion. The trial court agreed that the police trooper, who followed Defendant's car into a business park and interacted with Defendant after he stopped his vehicle, lacked the required reasonable articulable suspicion. The Supreme Court vacated the portion of the trial court's decision granting Defendant's motion to suppress, holding that the lower court erred in determining that the trooper seized Defendant by following him into the park, as Defendant was not subject to physical force or show of authority. Remanded. View "State v. Collier" on Justia Law

Following a jury trial, Defendant was convicted of one count of arson. The Supreme Court affirmed the judgment of conviction, holding (1) the indictment and jury verdict did not deprive Defendant of his constitutional right to be free of double jeopardy because the trial court consolidated two separate counts of arson based on one criminal act identified in the indictment and jury verdict and sentenced Defendant for only one count of arson; and (2) under the circumstances, the trial court did not deprive Defendant of his Sixth Amendment right to counsel when it overruled Defendant's objection to the testimony of an anticipating defense witness who decided, mid-trial, to testify for the prosecution in exchange for a promise of immunity. View "State v. Bellavance" on Justia Law

After a jury trial, Defendant was found guilty of burglary and theft by unauthorized taking or transfer for taking building materials worth more than $1,000. Defendant's adult son had told the police that he helped Defendant take the materials, but during the trial, he asserted his Fifth Amendment privilege against self-incrimination and refused to testify. On appeal, Defendant contended that the trial court erred when it admitted redacted versions of two statements his son made earlier to the police that incriminated both Defendant and his son. The Supreme Court vacated the judgment of conviction, holding that the trial court erred in admitting the statements of Defendant's son based both on the Rules of Evidence and the U.S. Constitution, and the error was not harmless. Remanded. View "State v. Larsen" on Justia Law

Defendant operated a returnable bottle redemption center. Defendant was convicted of theft by deception for turning over empty beverage containers that were not from beverages purchased in Maine and accepting deposit refunds and handling fees from Maine beverage distributors for those containers. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the conviction; (2) the trial court did not err in admitting evidence regarding bad acts committed outside the time alleged in the charging instrument; (3) a certain tactic employed by the prosecutor in the case amounted to prosecutorial error, but the error did not prejudice Defendant; and (5) the trial court did not err in failing to give requested jury instructions. View "State v. Woodard" on Justia Law

In 2007, Petitioner pleaded guilty to ten counts of burglary. Because of a pending federal sentence, Petitioner was classified as a medium security inmate by the Department of Corrections (DOC). In 2011, Petitioner filed a grievance with the DOC contending that he should have been receiving two days of good time per month pursuant to Me. Rev. Stat. 17-A, 1253(10)(B), which gives the chief administrative officer of a prison the discretion to deduct up to two days per month from an inmate's sentence for satisfactory performance in "community work, education or rehabilitation programs." The DOC denied relief. The superior court denied Petitioner's petitions seeking post-conviction relief. The Supreme Court affirmed, holding (1) the DOC properly construed section 1253(10)(B); and (2) the DOC's policy implementing section 1253(10)(B) was validly adopted in accordance with the Maine Administrative Procedure Act. View "Roderick v. State" on Justia Law

After a jury trial, Defendant was convicted of seven counts of unlawful sexual contact (Class C) and three counts of unlawful sexual contact (Class B). Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to a detective because he was not advised of his Miranda rights prior to his custodial interrogation and because his statements made prior to and after his arrest were involuntary. The Supreme Court vacated the judgment of conviction and remanded, holding (1) Defendant was not in custody for purposes of the Miranda requirements; but (2) the district court clearly erred in finding that Defendant's statements were voluntary. View "State v. Wiley" on Justia Law

Plaintiffs were sex offenders who were all initially required to register as sex offenders under Maine's Sex Offender Registration and Notification Act (SORNA) of 1999. Some Plaintiffs were later relieved of the registration requirement, but others remained on the registry and had viable claims. Plaintiffs filed actions against several State defendants, alleging, among other things, that SORNA of 1999 was an unconstitutional ex post facto law. The trial court granted the State defendants' motion for summary judgment, concluding that the cases of the Plaintiffs who successfully petitioned to be relieved from the duty to register were moot and that SORNA of 1999 as amended after State v. Letalien was constitutional. The Supreme Court affirmed the trial court's decision that SORNA of 1999 as amended following the Court's decision in Letalien did not violate the constitutional rights of the litigants. View "Doe v. Williams" on Justia Law

Defendant was charged by a fifty-nine-count indictment that included forty-five counts of violation of privacy and one count of conspiracy to commit violation of privacy. Defendant subsequently filed a motion to dismiss the violation of privacy counts, which the trial court granted, concluding that based on the indictment and the State's offer of proof, the State could not prove the crimes as alleged. The State appealed, contending that the court erred in granting the motion because it was untimely and the indictment adequately charged the offenses pursuant to the applicable statutes. The Supreme Court affirmed, holding that because the relevant counts of the indictment, as augmented by the State's offer of proof, failed adequately to charge the offense of violation of privacy, the court properly granted Defendant's motion to dismiss. View "State v. Strong" on Justia Law

Defendant and two co-conspirators pleaded no contest or guilty to various charges. Defendant pleaded guilty to two counts of intentional or knowing murder. The sentencing court sentenced Defendant to two concurrent terms of forty-five years in prison. Defendant appealed, arguing that the court abused its discretion in sentencing him to a longer prison term than that of his two co-conspirators. The Supreme Court affirmed the sentences, holding that, given the court's consideration of the purposes of sentencing, proper completion of the two-step sentencing procedure for murder, articulation of the reasons for the sentence, and explicit discussion of and adjustment for the sentencing inequality at issue, the sentencing court did not abuse its discretion in sentencing Defendant. View "State v. Hamel" on Justia Law

After the State brought a criminal proceeding against Mark Strong, the court initiated jury selection through a process that had the practical effect of excluding the public, including the media, from voir dire. After Maine Today Media, Inc.'s request that the court open the voir dire process to the public was denied, Maine Today filed a motion to intervene, which the trial court denied. Maine Today filed an interlocutory appeal. The Supreme Court (1) vacated the denial of the motion to intervene and allowed intervention for the limited purpose of the matters addressed in this appeal; and (2) vacated the court's order barring the public from the entirety of the voir dire process. Remanded to the trial court to conduct the remaining voir dire in a presumptively public manner. View "State v. Strong" on Justia Law