Articles Posted in Maine Supreme Judicial Court

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of aggravated assault. Defendant, a mixed martial arts fighter, repeatedly punched the victim in the head, rendering the victim unconscious. A jury found him guilty of aggravated assault. On appeal, Defendant argued that there was insufficient evidence to support his conviction and that there was insufficient evidence supporting a finding that the State disproved self-defense. The Supreme Court disagreed, holding that the State presented sufficient evidence to prove that Defendant manifested an extreme indifference to the value of human life and to disprove Defendant’s self-defense justification beyond a reasonable doubt. View "State v. Matthews" on Justia Law

by
The Supreme Judicial Court dismissed the appeal brought by Appellant challenging his sentence requiring him to pay $7,500 in restitution based on his involvement in damaging rental property from which he was evicted. The appeal was dismissed because Appellant did not properly assert that there was any illegality apparent on the record. Rather, Appellant challenged only the factual and discretionary determinations of the lower court. Because these are decisions that the Supreme Judicial Court does not review in a direct appeal of a sentence, the Court dismissed Appellant's appeal. View "State v. Plante" on Justia Law

by
The Supreme Judicial Court dismissed Appellant’s appeal from a judgment of conviction of manslaughter following Appellant’s unconditional open guilty plea, holding that Appellant provided no persuasive reason for the Court to depart from its longstanding jurisprudence strictly limiting direct appeal following a guilty plea. On appeal, Appellant argued that his plea was involuntary because he was coerced to accept the truth of all the facts recited by the State at the plea hearing and that he should not be required to show cause as to why his appeal should not be dismissed pursuant to State v. Huntley, 676 A.2d 501 (Me. 1996), and its progeny, which provide that a defendant may not appeal from a conviction entered upon his guilty plea except under certain circumstances. Because Appellant did not move to withdraw his unconditional plea before the court imposed the sentence and did not assert that the trial court lacked jurisdiction or that it imposed an excessive, cruel, or unusual sentence, this appeal must be dismissed. View "State v. Adams" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of conviction entered by the sentencing court following Defendant’s guilty plea to an information charging him with felony murder. The sentencing court imposed a prison sentence of twenty years, all but ten years suspended, with four years’ probation and a restitution order. On appeal, Defendant argued that his sentence was unconstitutionally disproportionate and denied his constitutional right to equal protection. The Supreme Judicial Court disagreed, holding (1) Defendant’s offense and sentence did not generate an “inference of gross disproportionality”; and (2) notwithstanding the fact that Defendant’s codefendant received only a seven-year sentence, Defendant’s sentence did not violate Defendant’s equal protection rights. View "State v. Lopez" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s sentence entered in the Unified Criminal Docket following Defendant’s guilty plea to two counts of aggravated criminal operating under the influence and possession of a firearm by a prohibited person. On appeal, Defendant argued that, notwithstanding an agreement with the State that his sentence would not exceed an agreed upon “cap,” the sentencing court was required to explain its selection of the basic, maximum, and final periods of incarceration. In affirming, the Supreme Judicial Court held that any error in the court’s articulation of the sentence was not sufficiently prejudicial to affect the outcome of the proceeding and did not affect Defendant’s substantial rights. View "State v. Bean" on Justia Law

by
The Supreme Judicial Court vacated the order of the trial court quashing Appellant’s subpoenas of mental health records of the alleged victim without first viewing the records in camera and remanded for the production and in camera review of some or all of the requested mental health records. Appellant was convicted of gross sexual assault of a person under the age of fourteen and unlawful sexual contact. On appeal, Appellant challenged the court’s decision to quash his subpoenas of the mental health records, the court’s denial of his motion to suppress statements made to law enforcement, and the court’s denial of his motion for a judgment of acquittal. The Supreme Court held (1) the trial court did not err in its rulings on either Appellant’s motion to suppress or his motion for a judgment of acquittal; but (2) because it was relatively certain that the records contained some evidence concerning the exact crimes charged, and the identity of the alleged perpetrator was directly at issue at trial, due process demanded that the court must proceed with an in camera review. View "State v. Olah" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder. The Court held (1) the trial court did not abuse its discretion or commit obvious error when it excluded evidence that the State of Maine’s Chief Medical Examiner had been removed from his former position as Chief Medical Examiner for the Commonwealth of Massachusetts; and (2) the trial court did not err, much less commit obvious error, when it instructed the jury on how it could evaluate evidence of flight to avoid prosecution. View "State v. Haji-Hassan" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder. The Court held (1) the trial court did not abuse its discretion or commit obvious error when it excluded evidence that the State of Maine’s Chief Medical Examiner had been removed from his former position as Chief Medical Examiner for the Commonwealth of Massachusetts; and (2) the trial court did not err, much less commit obvious error, when it instructed the jury on how it could evaluate evidence of flight to avoid prosecution. View "State v. Haji-Hassan" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s convictions for three counts of murder and one count of gross sexual assault and the sentences of life imprisonment imposed on each of the murder counts. The Court held (1) the trial court abused its discretion by foreclosing Defendant’s cross-examination of the State’s Chief Medical Examiner concerning his termination from his position as the Chief Medical Examiner in Massachusetts, but the error was harmless; (2) the trial court did not clearly err by finding that the State had sufficiently established the chain of custody of the sexual assault kit used during the autopsy of one of the victims; (3) there was sufficient evidence to support the jury’s guilty verdict on the gross sexual assault charge; (4) the State did not commit prosecutorial misconduct in its opening statement; and (5) the trial court applied a correct standard of proof and did not abuse its discretion in determining the facts considered at sentencing. View "State v. Coleman" on Justia Law

by
The Supreme Judicial Court affirmed Defendant’s convictions for three counts of murder and one count of gross sexual assault and the sentences of life imprisonment imposed on each of the murder counts. The Court held (1) the trial court abused its discretion by foreclosing Defendant’s cross-examination of the State’s Chief Medical Examiner concerning his termination from his position as the Chief Medical Examiner in Massachusetts, but the error was harmless; (2) the trial court did not clearly err by finding that the State had sufficiently established the chain of custody of the sexual assault kit used during the autopsy of one of the victims; (3) there was sufficient evidence to support the jury’s guilty verdict on the gross sexual assault charge; (4) the State did not commit prosecutorial misconduct in its opening statement; and (5) the trial court applied a correct standard of proof and did not abuse its discretion in determining the facts considered at sentencing. View "State v. Coleman" on Justia Law