Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court affirmed Defendant's conviction of manslaughter, holding that the trial court did not err in denying Defendant's motions for a judgment of acquittal and for a new trial. On appeal, Defendant argued that the trial court erred by denying his motion for judgment of acquittal and by denying his motion for a new trial based on allegedly improper arguments proffered by the State during its closing argument. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support the conviction; and (2) Defendant did not demonstrate that the trial court erred by allowing the State to refer to Defendant's disability in its closing argument. View "State v. Bilodeau" on Justia Law

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The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court after a jury found Defendant guilty of burglary and theft by unauthorized taking, holding that the trial court did not commit reversible error. On appeal, Defendant argued that the trial court erred in denying his motion to suppress portions of a surveillance video recording because other portions of the recording were not preserved and that the court committed obvious error by failing to intervene after several allegedly improper comments made by the prosecutor during closing argument. The Supreme Judicial Court affirmed, holding (1) the trial court's finding that the State did not act in bad faith when it failed to preserve the remainder of the recording did not constitute clear error, and therefore, the court did not err when it denied Defendant's motion to suppress; and (2) the majority of the prosecutor's statements challenged on appeal did not rise to the level of misconduct, and as to the remaining statement, the court's instructions clarified any misimpression that the prosecutor's comments may have created. View "State v. Chan" on Justia Law

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The Supreme Judicial Court vacated the judgments of conviction for both murder and robbery, holding that the instructions on the elements of robbery misstated the law and thereby also rendered erroneous a portion of the court's instructions on self-defense, requiring a new trial. Defendant was convicted of intentional or knowing murder and robbery. On appeal, Defendant argued that the trial court's jury instructions allowed the State to obtain a conviction without proof of every element of robbery as charged. The Supreme Judicial Court agreed, holding (1) the instructions on the elements of robbery made it possible that the jury reached a verdict based on impermissible criteria; (2) the error in the robbery instruction also affected the judgment of conviction of murder; and (3) the error seriously affected the fairness and integrity of the proceedings and may have affected the verdicts. View "State v. Asante" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of manslaughter and aggravated assault, holding that the trial court did not err in instructing the jury and that the evidence was sufficient to support the conviction. On appeal, Defendant argued (1) the trial court erred in denying his request to pose questions regarding self-defense and defense of another in the juror questionnaire, and (2) the evidence was insufficient to support a finding that Defendant's actions - rather than subsequent medical treatment - caused the victim's death. The Supreme Judicial Court affirmed, holding (1) while the court could have included an appropriate question regarding self-defense and defense of another, the court did not abuse its discretion in declining to include such a question; and (2) based on the evidence in there record, the jury could rationally have found beyond a reasonable doubt that the victim's death would not have occurred but for the conduct of Defendant and that the medical care was not clearly sufficient to cause the victim's death. View "State v. Limary" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of one count of Class B theft by deception and one count of Class C theft by deception, holding that there was no error in the proceedings below. On appeal, Defendant argued (1) the trial court erred by failing to include a “nexus” element in its instruction to the jury on the charge of theft by deception, (2) the evidence was insufficient to convict him of theft by deception, and (3) his actions constituted a breach of contract, not a criminal offense. The Supreme Judicial Court affirmed, holding (1) the jury rationally could have found beyond a reasonable doubt each element of theft by deception based on the testimonial and documentary evidence presented at trial and reasonable inferences drawn therefrom; (2) the evidence was sufficient to support the jury's verdict; and (3) Defendant waived his ability to challenge the jury instructions on appeal. View "State v. McLaughlin" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for manslaughter, holding that the evidence admitted at trial was sufficient to prove beyond a reasonable doubt that Defendant caused the child victim's death. Defendant was convicted of manslaughter for the death of a seven-month-old infant. The sentencing court sentenced Defendant to eleven years' imprisonment, with all but five years and six months suspended, and four years' probation. On appeal, Defendant challenged the sufficiency of the evidence. The Supreme Judicial Court affirmed, holding that the court was justified in finding beyond a reasonable doubt that Defendant, acting with criminal negligence, caused the child's death. View "State v. Mackin" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of five counts of unlawful sexual touching and one count of visual sexual aggression against a child, holding that Defendant received a fair trial with properly admitted expert testimony and a clear guilty verdict. After a third trial, Defendant was convicted and sentenced. On appeal, Defendant argued that the trial court erred in accepting the jury's verdict, that prosecutorial misconduct deprived him of a fair trial, and that the court erred in admitting the State's expert witness's testimony. The Supreme Judicial Court affirmed, holding that the court did not clearly err in finding the State's witness to be a qualified expert witness. View "State v. Westgate" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court terminating Defendant's deferred disposition and imposing sentence following his earlier guilty plea to trafficking in prison contraband, holding that the court did not err in admitting evidence at the termination hearing that had been suppressed in a separate criminal case. Defendant pleaded guilty to trafficking in prison contraband, and the court deferred disposition on that count. Defendant was subsequently indicted on new criminal charges. The court granted Defendant's motion to suppress evidence resulting from a police officer's search of his pocket on the basis that the search was unconstitutional. The State then dismissed the charges. In the first case, the State moved to terminate Defendant's deferred disposition based on his alleged new criminal conduct. Defendant sought an order continuing suppression of the evidence. The court denied Defendant's motion. The court then found that Defendant had violated the deferred disposition agreement and imposed sentence. The Supreme Judicial Court affirmed, holding that because the "sole purpose" of the exclusionary rule was satisfied by the exclusion of the evidence derived from the unlawful search in the dismissed criminal case, the trial court did not err in ruling that the suppressed evidence could be considered in the deferred disposition termination proceeding. View "State v. Hourdeh" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of depraved indifference murder pursuant to Me. Rev. Stat. 17-A, 201(1)(B), holding that the State presented sufficient evidence such that the fact-finder could have found each element proved beyond a reasonable doubt. Specifically, the Supreme Judicial Court held (1) the trial court did not err in finding Defendant guilty of murder because the State presented sufficient evidence to support the fact-finder's determination that the State had proved each element beyond a reasonable doubt; and (2) the trial court did not err or abuse its discretion when it limited Defendant's cross-examination of the State's Chief Medical Examiner. View "State v. Gatto" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for reckless conduct and aggravated criminal mischief, holding that the trial court did not abuse its discretion by offering Defendant a continuance of the trial in lieu of excluding his medical records. On appeal, Defendant argued that the trial court abused its discretion by denying his motion to suppress his personal medical records as a sanction for the State's late seizure of the records. The Supreme Judicial Court agreed that the State's conduct undermined the purpose of Maine Rule of Unified Criminal Procedure 18(b) but that the court's offer of a continuance in lieu of the exclusion of the evidence constituted an appropriate response to the State's conduct. View "State v. Mullen" on Justia Law