Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was found guilty of intentional or knowing murder for killing a sixteen-year-old girl, who was found buried with her wrists bound in duct tape, behind Defendant's mother's home. Defendant was sentenced to forty-seven years' incarceration. The Supreme Court affirmed. Defendant subsequently moved for additional DNA analysis and a new trial, claiming that a trace amount of male DNA previously found in a clipping from the duct tape had been further analyzed, and that Defendant was excluded as the source of that DNA. The post-conviction court denied Defendant's motion for a new trial, holding that the newly discovered DNA evidence did not make a different verdict probable due to the strong evidence of Defendant's guilt and the limited nature of the additional DNA test results. The Supreme Court affirmed, holding that the court did not err in its findings of fact, misapply the relevant statute, or abuse its discretion in denying the motion for a new trial. View "State v. Reese" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and criminal mischief. The Supreme Court affirmed, holding that the jury rationally could have found every element of the offenses beyond a reasonable doubt, as (1) the evidence presented was sufficient to support the jury's findings that Defendant obtained and intended to deprive the State of possession of property with a value greater than $1,000; and (2) the evidence was sufficient to support the jury's findings that Defendant intentionally, knowingly, or recklessly damaged or destroyed property of the State without reasonable grounds to do so. View "State v. Reed" on Justia Law

After a jury trial, Defendant was convicted for the intentional or knowing murder of his roommate. Defendant appealed, arguing that the trial court erred in concluding that he waived his Fifth Amendment privilege against self-incrimination and ordering him to answer a question posed by the State on cross-examination. The Supreme Court affirmed the conviction, holding that the trial court did not abuse its discretion (1) in determining that Defendant waived his Fifth Amendment privilege and in reasoning that the disputed question posed by the State was within the scope of his testimony on direct examination; and (2) in instructing the jurors that they could consider Defendant's unprivileged refusal to answer the State's question on cross-examination. View "State v. Butsitsi" on Justia Law

In the late 1990s, Bryan Carrier pled guilty to three counts of vehicular manslaughter and three counts of aggravated operating under the influence. The judgment and commitment notified Defendant that his license was suspended for life on the manslaughter counts. In 2011, Carrier petitioned for reinstatement of his license. After a hearing, a hearing officer of the Secretary of State's Bureau of Motor Vehicles denied Carrier's petition based on the opposition of the victims' families. The superior court denied Carrier's petition for judicial review. The Supreme Court affirmed, holding that the reinstatement statute allows for consideration of the opinions of the victims and their families. View "Carrier v. Sec'y of State" on Justia Law

After a jury trial, Defendant was convicted of intentional and knowing murder. The trial court sentenced Defendant to thirty-five years in prison. Defendant appealed, arguing (1) the court erred in denying him a new trial based on the State's failure to produce exculpatory evidence, (2) the court violated the equal protection right of a juror removed from the panel given his inability to deliberate past 5:08 p.m. for religious reasons, and (3) there was insufficient evidence to support his conviction. The Supreme Court affirmed the judgment, holding (1) Defendant received a fair trial in this matter; (2) there was no disparate treatment of the juror, and therefore, the juror's equal protection rights were not violated; and (3) there was no error in the trial court's entry of the judgment of conviction or its sentencing analysis. View "State v. Carr" on Justia Law

Following a nonjury trial, Defendant was convicted of domestic violence assault. Defendant's sentence included a period of two years of probation with a requirement that he participate in a certified batterers' intervention program. Defendant contended that his sentence violated the Equal Protection clauses of the U.S. and Maine Constitutions because, he asserted, a woman convicted of the same crime could not be sentenced to a term of probation of more than one year. The Supreme Court vacated the sentence and remanded for additional proceedings because there was no factual record from which the Court could evaluate Defendant's and the State's arguments. View "State v. Mosher" on Justia Law

Defendant appealed from a judgment of conviction of one count of murder and one count of manslaughter entered in the trial court following a jury trial. Defendant argued that the trial court erred in denying his motion to suppress a confession, other statements, and physical evidence found as a result of the statements. The Supreme Court affirmed the judgment, holding that the trial court did not err in (1) finding Defendant was not in custody during the first interrogation; (2) failing to suppress Defendant's post-warning statements because the detectives' actions did not reflect a deliberate strategy to use "Miranda-in-the-middle," a two-step interrogation procedure; and (3) concluding that the State proved beyond a reasonable doubt that Defendant's post-warning statements were voluntary in light of the totality of the circumstances. View "State v. Nightingale" on Justia Law

Defendant was charged with the murder of her estranged husband. Following a jury trial, Defendant was found guilty of attempted murder, elevated aggravated assault, and false public alarm or report. Defendant appealed, asserting that the trial court made several evidentiary errors and that improper statements made by the prosecutor during the trial constituted prosecutorial misconduct that deprived her of a fair trial. The Supreme Court concluded that no evidentiary errors occurred and focused its discussion on Defendant's assertions of prosecutorial misconduct. The Court affirmed the judgment, holding that any prosecutorial misconduct, even considered cumulatively, did not affect the jury's verdict, and therefore, Defendant received a fair trial. View "State v. Dolloff" on Justia Law

Defendant appealed from a judgment of conviction entered in the trial court finding him guilty of four counts of criminal threatening with a dangerous weapon, eleven counts of criminal restraint with a dangerous weapon, twenty-two counts of kidnapping, one count of burglary, and one count of criminal restraint. The Supreme Court affirmed, holding (1) Defendant was not denied his right to speedy trial; (2) Defendant was not denied his right to self-representation; (3) the jury instructions accurately and fairly informed the jury in all necessary aspects of the law; (4) the court did not err by not dismissing the kidnapping charge; (5) there was sufficient evidence for the jury to find Defendant held the kidnapping victims for a "substantial period of time"; and (6) the court properly imposed consecutive sentences. View "State v. Hofland" on Justia Law

Defendant appealed from a judgment of conviction entered by the trial court following his conditional guilty plea to manslaughter. Defendant contended (1) the trial court erred in denying his motion to suppress statements he made to police officers during the investigation of his infant daughter's death, and (2) the juvenile court erred by admitting hearsay evidence during Defendant's juvenile bind-over hearing. The Supreme Court affirmed the judgment, holding (1) any statements made by Defendant during interrogations were not subject to the requirements of Miranda and were therefore not excludable on those grounds, the court properly considered Defendant's juvenile status, and the court did not err in concluding that Defendant's confession was voluntary; and (2) the court did not err by treating the hearsay testimony during the bind-over hearing as reliable, and therefore, its admission was not error. View "State v. Jones" on Justia Law