Articles Posted in Maine Supreme Judicial Court

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The Supreme Judicial Court affirmed Defendant's convictions of eluding an officer, driving to endanger, criminal speeding, and operating after suspension, holding that the trial court did not abuse its discretion. On appeal, Defendant argued that trial court erred by interfering with the State's decision in deciding whether to dismiss the case, in violation of the doctrine of the separation of powers, and by admitting into evidence a photograph taken at the time of his arrest. The Supreme Judicial Court disagreed, holding (1) the court made it clear that the prosecutor was the decision-maker as to whether to dismiss the case; and (2) the court acted within the bounds of its discretion by admitting the photograph. View "State v. Pelletier" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the district court entering a protection from harassment order against Defendant on the complaint of Jane Doe, holding that the court did not err in issuing the protection from harassment order. Specifically, the Court held (1) the district court did not abuse its discretion in consolidating the hearing on Defendant's motion to dissolve the temporary protection from harassment order and the final hearing on Doe's complaint; (2) the district court did not abuse its discretion in issuing a scheduling order that limited the time for the consolidated hearing to two hours; and (3) the district court did not err in finding credible the testimony of two witnesses and in finding that Defendant intentionally sought to harass Doe. View "Doe v. Plourde" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for manslaughter entered after a jury trial, holding that any error in admitting certain testimony and in challenged remarks made by the prosecutor during closing argument did not require reversal of the conviction. Specifically, the Court held (1) Defendant failed to preserve for review her objection to the admission of certain testimony, and a challenged statement by another witness was not unfairly prejudicial; (2) certain misstatements made by the State during its closing argument did not rise to the level of prosecutorial misconduct; (3) the evidence was sufficient to support the conviction; (4) the trial court did not abuse its discretion in denying Defendant's motion for voir dire and a new trial based on allegations of juror misconduct; and (5) Defendant's sentence is constitutional. View "State v. Scott" on Justia Law

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The Supreme Judicial Court affirmed the judgment of divorce entered by the district court after a contested hearing and the court's denial of Father's post-judgment motions to alter or amend the judgment or for a new trial, holding that there was no error in the court's factual findings or any abuse of discretion in its awarding primary residence of the parties' minor child to Mother and establishing a gradually increasing contact schedule for Father. On appeal, Father argued that because the trial judge recused himself sua sponte after the judgment was entered, there may have been undue prejudice by the judge due to the judge's participation in other proceedings involving Father. The Supreme Court affirmed, holding that the record provided no support for Father's claim that the trial judge erred in failing to recuse himself sua sponte during the trial. The Court remanded the matter for further proceedings on Mother's request for attorney fees. View "Schafer v. Schafer" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of theft by unauthorized taking of a firearm and other offenses, holding that the evidence was sufficient to support the convictions and that the court did not err in admitting certain testimony pursuant to the excited utterance exception to the hearsay rule. Specifically, the Court held (1) the evidence was sufficient to support Defendant's conviction of unlawful possession of scheduled drugs; (2) the evidence was sufficient to support Defendant's convictions for theft of a firearm and domestic violence criminal threatening; and (3) the trial court did not err by admitting a witness's testimony regarding statements Defendant's girlfriend made to him after Defendant left the house upon concluding that those statements qualified as excited utterances. View "State v. Curtis" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court dismissing Defendant's petition for post-conviction review as untimely filed, holding that, contrary to Defendant's contention on appeal, the court was not precluded from summarily dismissing the petition based on the statutory filing deadline. Defendant pleaded guilty to aggravated trafficking in scheduled drugs and illegal importation of scheduled drugs. Defendant filed a petition for postconviction review seeking to collaterally attack his conviction on the basis of ineffective assistance of counsel. The trial counsel dismissed the petition as untimely filed. On appeal, Defendant argued that the court erred in determining that there is no duty imposed on trial counsel or the sentencing court to inform Defendant about the deadlines for filing a post-conviction review petition. The Supreme Judicial Court disagreed, holding (1) this Court declines Defendant's invitation to impose a new obligation on sentencing courts to inform defendants about the filing deadline set out in Me. Rev. Stat. 15, 2128-B; (2) trial counsel's failure to inform Defendant of the filing deadline for post-conviction review petitions did not constitute ineffective assistance of counsel or preclude enforcement of the filing deadline. View "Roque v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for burglary, stealing drugs, and violation of a condition of release, holding that the trial court did not err when it denied Defendant's motion to suppress al evidence obtained as a result of the State's acquisition of Defendant's cell phone's location information (CSLI). Specifically, the Supreme Court held (1) because Defendant lacked standing to challenge evidence obtained as a result of the acquisition of a coperpetrator's CLSI, which was the same evidence Defendant sought to exclude based on the acquisition of his own CSLI, this Court need not decide whether the acquisition of Defendant's CSLI was a search under the Fourth Amendment; (2) whether the State violated Defendant's rights under Maine's Electronic Device Location information Act, 16 Me. Rev. Stat. 647 to 650-B, was irrelevant to whether the court erred in denying Defendant's motion to suppress; and (3) the entry into and search of Defendant's residence were lawful. View "State v. O'Donnell" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of manslaughter after a conditional guilty plea, holding that the State provided sufficient evidence, independent of Defendant's multiple confessions, to establish corpus delicti for the alleged homicide of Defendant's infant son. On appeal, the Court held (1) the trial court made several factual findings, supported by competent evidence in the record, that were sufficient to establish a substantial belief that the infant's death was a result of criminal agency; and (2) there was no reason to depart from the well-established corpus delicti doctrine and to adopt the federal "trustworthiness" standard. View "State v. Hagar" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions but remanded the case for resentencing, holding that the prosecutor did not engage in misconduct during opening statements but that the trial court erred by imposing a sentence within the enhanced range provided by the version of Me. Rev. Stat. Ann. 17-A, 1252(2)(A) that became effective on September 29, 1995. After a jury trial, Defendant was convicted of three counts of gross sexual assault of a person under the age of fourteen and two counts of unlawful sexual contact. The trial court sentenced Defendant to twenty-four years' imprisonment, all but sixteen years suspended, with probation for six years. Defendant appealed. The Supreme Judicial Court affirmed, holding (1) Defendant failed to demonstrate obvious error in the prosecutor's act of alluding to Defendant's supposed confession in his opening statement without ever presenting testimony to support that contention; and (2) Defendant's right to a jury trial was violated when the trial court enhanced the penalty for Defendant's crime beyond what was statutorily authorized after finding an additional fact not pleaded and proved to the jury. View "State v. Pelletier" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence (OUI), holding that the court did not err in concluding beyond a reasonable doubt that Defendant had operated a motor vehicle while intoxicated, in violation of Me. Rev. Stat. 29-A, 2411(1-A)(A). On appeal, Defendant argued that there was insufficient evidence for the court to have found, beyond a reasonable doubt, that Defendant operated a motor vehicle while under the influence. The Supreme Judicial Court disagreed, holding that the court's findings were supported by competent evidence in the record that was sufficient to allow a fact-finder to rationally conclude beyond a reasonable doubt that Defendant operated a motor vehicle while under the influence. View "State v. Bittues" on Justia Law