Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court affirmed in part and vacated in part Defendant's judgment of conviction of gross sexual assault, unlawful sexual contact, sexual abuse of a minor, and unlawful sexual touching, holding that there was insufficient evidence to support the convictions of gross sexual assault and unlawful sexual contact. The Supreme Judicial Court remanded the case for resentencing, holding (1) there was sufficient evidence to support Defendant's convictions for sexual abuse of a minor and unlawful sexual touching; and (2) because the State did not present any evidence that Defendant, a substitute teacher, possessed the requisite authority over the victim, a student, at the time that he committed the sexual act and sexual contact, there was insufficient evidence to convict Defendant of gross sexual assault and unlawful sexual contact. View "State v. Conroy" on Justia Law

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The Supreme Judicial Court affirmed Defendant's judgment of conviction of two counts of stalking and two counts of harassment entered by the trial court after a jury trial, holding that the court did not err or abuse its discretion. Specifically, the Court held (1) the trial court did not violate Defendant's right to a fair trial; (2) the judgment entered in Defendant's favor in a prior protection from harassment matter was not entitled to res judicator effect in this criminal prosecution; (3) the trial court did not err when it allowed one of the victims to testify that a lawsuit Defendant filed against the victim was dismissed with prejudice; (4) the trial court did not err in denying Defendant's motions for judgment of acquittal; and (5) the trial court committed no obvious error in failing to give three jury instructions. View "State v. Williams" on Justia Law

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The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court as a result of a jury verdict finding Defendant guilty of two counts of manslaughter, two counts of causing a death while operating under the influence, and related charges, holding that the court did not err when it denied Defendant's motion to suppress the results of a warrantless blood draw taken at the scene of a fatal motor vehicle accident. Me. Rev. Stat. 29-A, 2522(2) directs law enforcement officers to test the blood of all drivers involved in a fatal, or likely fatal, motor vehicle accident without any requirement of probable cause before the blood draw. Defendant argued on appeal that the statute is unconstitutional on its face. The Supreme Judicial Court agreed but nonetheless affirmed the trial court's denial of Defendant's motion to suppress, holding (1) Me. Rev. Stat. 29-A, 2522(2) violates the Fourth Amendment because it does not require that law enforcement have consent or probable cause to believe that a driver is impaired before drawing a person's blood; but (2) the trial court correctly denied Defendant's motion to suppress because the "good faith" exception to the exclusionary rule applied to the search. View "State v. Weddle" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault, holding that the evidence was sufficient to support the trial court's finding that Defendant possessed the requisite mens rea. On appeal, Defendant argued that Me. Rev. Stat. 17-A, 253(2)(M) must be read to require proof that he knew that the person with whom he was engaging in a sexual act had not expressly or impliedly acquiesced to the sexual act and that the evidence was insufficient to support a finding that he knew the victim had not expressly or impliedly acquiesced to the sexual activity. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support a finding that Defendant engaged in a sexual act that he knew the victim had not expressly or impliedly acquiesced to. View "State v. Asaad" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of robbery and unlawful possession of scheduled drugs, holding that the trial court did not err by overruling Defendant's objection to an aspect of the State’s closing argument, and Defendant was not denied a fair trial because the court failed to address sua sponte the State’s alleged misstatement of evidence in its rebuttal argument. Specifically, the Supreme Judicial Court held (1) the State did not commit prosecutorial misconduct during its closing argument by overruling Defendant's objection to an argument that Defendant argued improperly suggested that Defendant had the burden of proof; and (2) any mischaracterization of the evidence by the State was not of such magnitude to have required the court to intervene sua sponte. View "State v. Sousa" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of two counts of aggravated assault and one count of assault a child younger than six years old, holding that there was no prosecutorial misconduct, the trial court's jury instructions did not constitute obvious error, and there was sufficient evidence in the record to support the jury's verdict. Specifically, the Court held (1) the State did not engage in prosecutorial misconduct during the trial; (2) there was no obvious error in the trial court's instructions to the jury on the elements of the aggravated assault charges; and (3) the evidence was insufficient to support the conviction for one of the aggravated assault charges. View "State v. Coleman" on Justia Law

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The Supreme Judicial Court affirmed Defendant's judgment of conviction of manslaughter following a jury trial on an indictment for murder, holding that the trial court did not clearly err or abuse its discretion in the proceedings below. Specifically, the Court held that the trial court (1) acted within its discretion in its conduct of voir dire, which addressed virtually all of Defendant's concerns; (2) did not clearly err in admitting a photograph of the victim with his son and acted within its discretion in overruling Defendant's Rule 403 objection; and (3) did not abuse its discretion by giving a curative instruction after the prosecutor misstated the evidence during closing arguments because the curative instruction adequately remedied any prejudice to Defendant. View "State v. Bethea" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of operating under the influence, operating after suspension, and criminal speeding, holding that the court's instructions contained obvious error by informing the jury that it could consider evidence of a failure to submit to a test on the issue of operation. On appeal, Defendant argued that he did not receive a fair trial because the jury was instructed about how it could properly consider evidence of his failure to submit to a breath or blood alcohol test. The Supreme Court agreed and remanded the case for a new trial, holding (1) because the jury instructions misstated the law and remained incorrect by any other component of the jury charge the instructions constituted plain error; and (2) the error rose to the level of obvious error because there was a reasonable probability that it affected the outcome of the trial and Defendant's substantial rights. View "State v. Thurlow" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder entered by the trial court after a jury-waived trial, holding that that the court did not err in admitting certain testimony given by the mother of the victim and that the sentence was without error. Specifically, the Court held (1) the trial court erred in admitting the mother's hearsay testimony, but the error was harmless because it was highly probable that the error did not affect the factfinder's judgment; and (2) the court did not "double-count" the factor of domestic violence in reaching its sentence. View "State v. Sweeney" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of two counts of intentional or knowing murder, holding that the trial court did not err in denying Defendant's motion to suppress evidence of his cell site location information (CSLI). On appeal, Defendant argued that the judge who issued the warrant permitting officers to obtain his CLSI erred in determining that there was probable cause supporting the warrant's issuance. The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence of his CSLI, holding that the information in the affidavit was sufficient to support the judge's determination that there was probable cause to believe that Defendant was involved in the two homicides and that his CSLI would contain or constitute evidence relevant to the crime. View "State v. Marble" on Justia Law