Articles Posted in Maine Supreme Judicial Court

by
The Supreme Judicial Court vacated the aggravating factors that elevated Defendants’ crime from Class B trafficking in schedule drugs to Class A aggravated trafficking in schedule W drugs, holding that there was insufficient evidence to convict Defendant of all four counts. The State charged Defendant with four counts of Class A aggravated trafficking in schedule W drugs. The jury returned a guilty verdict on all four counts. On appeal, Defendant challenged the sufficiency of the evidence supporting his conviction. The Supreme Judicial Court vacated the aggravating elements of Defendant’s convictions and remanded for resentencing on four counts of trafficking in schedule W drugs, holding (1) Me. Rev. Stat. 17-A, 1105-A(1)(E) requires proof beyond a reasonable doubt that the locus of the drug trafficker at the time of the offense be within 1,000 feet of the real property of a school, measured in a straight line and accounting for any difference in elevation between the two points; and (2) there was insufficient evidence that Defendant trafficked within 1,000 feet of a school. View "State v. Brown" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence and operating beyond a license condition or restriction, holding that the trial court did not err by excluding testimony of two witnesses that Defendant had designated as experts. Defendant designated the two experts to testify that, at the time of his arrest, he had a condition known as “auto-brewery syndrome,” a phenomenon associated with the production of alcohol within the body itself under certain circumstances. The Supreme Court affirmed the trial court’s judgment, holding (1) the record supported the trial court’s findings that Defendant’s first witness was not sufficiently qualified to testify generally about auto-brewery syndrome and did not have a sufficient basis to opine that Defendant had that condition at the time of his arrest; and (2) the trial court properly excluded testimony of Defendant’s second proposed expert witness because of Defendant’s significant delay in designating her. View "State v. Burbank" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s conviction of murder and elevated aggravated assault with a firearm, holding that there was sufficient evidence to support the convictions and that the trial court did not err in its instructions to the jury. On appeal, Defendant argued that the trial court erred by (1) denying his requested jury instruction on eyewitness identification and by giving an inadequate instruction on eyewitness identification, and (2) overemphasizing the definition of accomplice liability in instructing the jury. The Supreme Judicial Court disagreed, holding (1) the trial court did not err in denying Defendant’s proposed jury instruction; (2) the trial court did not err in its instruction on accomplice liability; and (3) there was sufficient evidence to support Defendant’s conviction for murder and elevated aggravated assault. View "State v. Hansley" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of conviction entered by the superior court after a jury verdict finding Defendant guilty of unlawful sexual contact and assault, holding that the superior court did not err in admitting part of a report of a sexual assault forensic examination (SAFE) performed on the adult female victim upon her arrival at Maine General Hospital. On appeal, Defendant challenged the admission of the report, arguing that the admitted portion did not satisfy the requirements of Me. R. Evid. 803(4). Defendant also argued that, even if the report were admissible, it was cumulative or unduly prejudicial and should have been excluded pursuant to Me. R. Evid. 403. The Supreme Judicial Court affirmed, holding (1) a SAFE report may be admitted over a hearsay objection if it also meets all other evidentiary rules and complies with the requirements of Me. Rev. Stat. 16, 357; (2) the superior court did not err in determining that the State had satisfied the requirements set forth in section 357; and (3) the court did not err in concluding that the probative value of the report was not outweighed by the danger of unfair prejudice. View "State v. Jones" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the superior court denying Appellant’s motion for a new trial brought pursuant to Maine’s post-conviction DNA analysis statute, 15 Me. Rev. Stat. 2136-2138, holding that, under the circumstances, the superior court did not err in denying Appellant’s motion for a new trial. Appellant was convicted of two counts of murder. Appellant later filed a motion for a new trial based on mitochondrial DNA testing performed at his request. The superior court denied Appellant’s request for a new trial following an evidentiary hearing. The Supreme Judicial Court affirmed, holding that the superior court did not err in its determination that Appellant failed to prove by clear and convincing evidence that the evidence found on the victim and tested pursuant to Appellant’s DNA testing request could only have come from the perpetrator of the crime. View "State v. Cookson" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder and imposing a forty-five-year sentence of incarceration, holding that the trial court did not err or abuse its discretion in the proceedings below. Specifically, the Supreme Judicial Court held that the trial court (1) did not abuse its discretion in the way it considered alternative suspect evidence; (2) did not abuse its discretion by excluding the opinion testimony of a Maine State Police detective; and (3) did not err in finding that Defendant had waived his religious privilege by repeating to his family members and law enforcement officers portions of statements that he had made to a pastor. View "State v. Fournier" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of three counts of possession of sexually explicit material of a minor under age twelve, holding that the court did not err in denying Defendant’s motion to suppress evidence seized pursuant to a search warrant. On appeal, Defendant argued that the search warrant was stale, failed to describe the items to be seized with “scrupulous exactitude,” as required by the First Amendment, and otherwise failed to describe the places to be searched and the items to be seized with sufficient particularity. The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress, holding (1) the trial court did not err in ruling that the information the court relied on was not stale; (2) the warrant’s description of the items to be seized and the purpose for their seizure did not implicate the heightened “scrupulous exactitude” standard; and (3) the warrant was not overbroad and satisfied the constitutional requirement for particularity. View "State v. Roy" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s conviction of murder and elevated aggravated assault, entered after a bench trial, holding that there was no error in the proceedings below. Specifically, the Court held (1) the evidence was sufficient to support the trial court’s factual findings, as well as its ultimately finding that Defendant was at least an accomplice in the murder and assault; (2) Defendant was not denied the due process guaranteed by the Fourteenth Amendment during trial; (3) the trial court did not err in allowing two witnesses to identify Defendant in court; and (4) the court did not err or abuse its discretion in certain evidentiary rulings challenged by Defendant on appeal. View "State v. Ferguson" on Justia Law

by
The Supreme Judicial Court vacated the order to enforce payment of restitution entered by the superior court following a hearing on a motion to enforce payment of a restitution obligation originally imposed as part of a sentence, holding that the motion court erred in imposing the burden on Defendant to prove the current balance of the court-ordered restitution for the victim’s uncompensated losses. Specifically, the Supreme Judicial Court held that the State never met the burden assigned to it in State v. Nelson, 994 A.2d 808 (Me. 2010), and State v. Berube, 698 A.2d 509 (Me. 1997), to determine the amount of the victim’s loss, payments credited to cover that loss, an thus the remaining sum that Defendant should have been obligated to pay in restitution. Because the State did not meet its burden to establish the amount still owed when it filed its motion to enforce the restitution obligation, the Supreme Judicial Court remanded for a new hearing on the enforcement of the restitution obligation with the State having the burden to prove the restitution obligation remaining. View "State v. Gagne" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s conviction of operating under the influence (OUI) with a refusal to submit to a chemical test, holding that the jury instructions given in this case were not confusing to the jury. Here, the State presented two alternative theories of guilt - principal liability and accomplice liability. On appeal, Defendant argued that the trial court abused its discretion when it denied his motion for a new trial because the jury instructions on a driver’s duty to submit to a chemical test and on accomplice liability confused the jury and did not provide a roadmap for the jury to be able to return a not guilty verdict. The Supreme Judicial Court affirmed after clarifying and distinguishing the two alternate theories, holding (1) the jury instructions were clear that the refusal instruction was inapplicable to the charge of accomplice liability in an OUI case; and (2) there was no prejudice to Defendant that resulted in an unfair trial. View "State v. Perkins" on Justia Law