Justia Criminal Law Opinion Summaries

After a jury trial, Defendant Colin Koehler was found guilty of the intentional or knowing murder of a young woman he had known for less than a day, for which the court sentenced him to life in prison. On appeal, Defendant challenged several rulings on evidence, procedure, motions, and jury instructions. He also challenged his sentence primarily on the grounds that there was insufficient evidence of premeditation, that he has no substantial criminal history, and that his mental health evaluations failed to reveal any significant psychological or psychiatric disorders linked to criminality. Upon review, the Supreme Court found no error in the trial court’s rulings and concluded that the court acted within its sentencing authority in imposing a life sentence.

Defendant Jacklyne S. Poole appealed her conviction on domestic violence assault following a bench trial. Defendant's charge arose from an incident in which she assaulted her boyfriend. She was sentenced to 180 days in jail, all suspended, and one year of probation. On appeal, Defendant argued: (1) that the court erred by denying her motion to enlarge time to file a jury trial request after the twenty-one-day deadline imposed by M.R. Crim. P. 22 because she did not knowingly and intelligently waive her right to a jury trial at arraignment; and (2) the application of different procedural rules for accessing the jury trial right in courts with and without Unified Criminal Dockets violated the federal and Maine constitutional guarantees of equal protection. Upon review, the Supreme Court found no error in the trial court's decisions, and affirmed the judgment.

Defendant Kevin Jones appealed a district court's judgment following a bench trial at which he was found guilty of carrying a concealed weapon. On appeal, Defendant argued that the evidence was insufficient to establish beyond a reasonable doubt that knives he carried were statutorily prohibited from being concealed. Because the statute's prohibitions applicable to knives are limited to those knives that, in their design or primary function, constitute a "dangerous or deadly weapon usually employed in the attack on or defense of a person," the Supreme Court vacated the conviction.

Defendant Bradley Lemay appealed his convictions of felony gross sexual assault; criminal threatening with a dangerous weapon' eluding an officer; attempted escape; and tampering with a victim. The charges stemmed from three events that occurred on three different dates. Defendant argued that the court abused its discretion by joining the matters for trial pursuant to M.R. Crim. P. 8(a), and by subsequently denying his motion for relief from prejudicial joinder pursuant to M.R. Crim. P. 8(d). Upon review, the Supreme Court affirmed: "The record makes clear that the court carefully considered and thoroughly evaluated Lemay’s arguments. The court also took care to give relevant instructions to the jury to reduce the potential for prejudice resulting from the joinder. Lemay failed to prove that any inadmissible evidence would be or was admitted due to the joinder, or that his choice not to testify interfered with his ability to present his defense. Given that the trial court has wide discretion to join and sever trials, on this record it was not an abuse of discretion for the court to ultimately conclude that the balance in this case tipped in favor of joinder."

Defendant Rogers Harrell appealed his conviction on domestic violence charges for which he received seven months' incarceration and a fine of $300. On appeal, Defendant argued that the fine was not mandatory, and that the sentencing court erred in concluding that the domestic-violence-assault statute incorporated the minimum fine mandated by the simple-assault statute. Upon review, the Supreme Court agreed with Defendant's argument and vacated the fine.

Richard Herzog was convicted of domestic violence assault and sentenced to twenty days in jail, all suspended, and two years of probation with conditions, including the condition that Herzog could not possess or use unlawful drugs or alcohol. The Supreme Court (1) affirmed the judgment of conviction, holding that the district court properly applied the law of self-defense and did not err in its factual findings; and (2) affirmed the sentence as modified, holding that the term of probation exceeded the statutory maximum, and thus, the sentence was adjusted to decrease the period of probation from two years to one year.

Following a jury trial, Timothy Mooney was found guilty of trafficking in prison contraband. Mooney appealed, arguing that the superior court erred by (1) allowing a corrections officer to testify about details of the incident giving rise to Mooney's criminal charge, and (2) allowing an investigator to testify as to additional charges that would have been brought against Mooney had another inmate cooperated with the investigation. The Supreme Court vacated Mooney's conviction, holding (1) the trial court did not abuse its discretion by admitting the corrections officer's testimony; (2) the trial court erred by admitting the investigator's irrelevant testimony in evidence; and (3) the error was not harmless.

Following a jury-waived trial, Peter DeGennaro was convicted of theft by unauthorized taking or transfer. DeGennaro appealed, contending that the evidence was insufficient as a matter of law to support the superior court's finding that he unlawfully controlled "the property of another" and insufficient as a matter of fact to support the court's finding concerning his intent. The Supreme Court affirmed, holding (1) the charge in the indictment that DeGennaro committed theft by unauthorized taking was also a charge that he committed any other theft offense under chapter 15 of the Criminal Code that the evidence supported; and (2) pursuant to the consolidation section of the statutory chapter setting out theft offenses, the evidence was sufficient to support a finding that DeGennaro was guilty of theft by deception.

Defendant Cory LaForge was charged with criminal operating under the influence. LaForge filed a motion to suppress evidence obtained as a result of the stop of his vehicle, arguing that the stop was not justified by an objectively reasonable suspicion of criminal conduct. The district court agreed and granted LaForge's motion. The Supreme Court vacated the suppression order, holding that, as matter of law based on the facts found by the motion judge, the stop of LaForge's vehicle by a police officer was justified based on an objectively reasonable articulable suspicion. Remanded for entry of an order denying the motion to suppress.

Following a joint jury trial, Jeffrey Williams was convicted of intentional or knowing murder and conspiracy to commit murder. The Supreme Court affirmed Williams's convictions, holding (1) Williams was not denied a fair trial when the court denied his motion to sever the trial, or, in the alternative, to hold a joint trial but with a separate jury for each defendant; (2) the court did not abuse its discretion in prohibiting cross-examination of a cooperating witness regarding Williams's prior arrests; (3) certain comments by the prosecutor in relation to the cooperating witness did not constitute improper vouching; and (4) the evidence was sufficient to support Williams's convictions.