Articles Posted in Maine Supreme Judicial Court

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The Supreme Judicial Court affirmed Defendant's conviction of aggravated criminal mischief and did not reach the State's claim of error on cross-appeal, holding that the evidence was sufficient for the jury to rationally find and conclude that the State proved each element of the offense of aggravated criminal mischief beyond a reasonable doubt. On appeal, Defendant argued that the State had not proved that he had damaged the "property of another" - a critical element of aggravated criminal mischief. On cross-appeal, the State challenged the denial of its motion to correct the sentence because the court did not order restitution. The Supreme Judicial Court affirmed, holding (1) the jury rationally could have inferred that Defendant intentionally, knowingly, or recklessly caused damage to the property of another; and (2) because the State failed to file an appeal and obtain the written approval of the Attorney General to appeal the court's decision, this Court did not reach the State's claim of error. View "State v. Ouellette" on Justia Law

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The Supreme Judicial Court vacated Defendant's convictions for failure to sign a criminal summons, refusing to submit to arrest by physical force, and assault, holding that the trial court abused its discretion by excluding from evidence a cellphone video taken by the defendant's sister that showed some of the events that occurred during Defendant's arrest. Specifically, the Court held (1) because the trial court did not rely on Me. R. Evid. 403 when excluding the video at issue and because the video was properly authenticated, the court's refusal to admit the video so that the jury could view it was an abuse of discretion; and (2) the trial court's exclusion of the video was not harmless error. View "State v. Hussein" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review alleging ineffective assistance of counsel in his probation revocation matter but that Appellant may file a motion for a new probation revocation hearing in the trial court within thirty-five days of the issuance of this mandate. The trial court concluded that Appellant's remedy for any claim of error arising from the revocation was to seek a discretionary appeal, as Appellant had already done. The Supreme Judicial Court held (1) in a probation revocation hearing, a defendant has a right to the effective assistance of counsel; (2) Appellant's motion was properly dismissed, but Appellant was deprived of an opportunity to obtain meaningful review on his claim; and (3) a defendant who seeks to raise a claim of ineffective assistance of counsel after a probation revocation hearing may do so by filing a motion under Rule 33 of the Maine Rules of Unified Criminal Procedure for a new trial, which must be filed thirty-five days after the entry of judgment, and the judge who issued the revocation judgment will, if the defendant has made out a prima facie claim of ineffective assistance, will hold an evidentiary hearing or dismiss the motion. View "Petgrave v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of operating under the influence, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained from a blood draw and that the court's jury instructions were sufficient and appropriate. Prior to trial court, Defendant filed a motion to suppress evidence from the blood draw and the corresponding blood-alcohol test result, arguing that the evidence was obtained without valid consent. The trial court denied the motion. After closing arguments, Defendant requested a curative instruction to remedy the State's alleged misstatement of the evidence in its closing argument. The court declined to give such an instruction. The jury subsequently found Defendant guilty of operating under the influence. The Supreme Judicial Court affirmed, holding (1) Defendant had the capacity to give knowing consent to the blood draw, and his consent was voluntary; and (2) the prosecutor's closing statements to the jury did not misstate the evidence, demonstrate bad faith, or create any prejudice. View "State v. Ayotte" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder, holding that the court did not abuse its discretion by admitting Facebook Messenger records into evidence and that there was sufficient evidence to support the jury's verdict. On appeal, Defendant argued that the court erred in admitting Facebook Messenger records because they were not properly authenticated and that they were improperly admitted pursuant to the hearsay exception that allows for the admission of a declarant's statement of his then-existing statement of mind. The Supreme Judicial Court affirmed, holding (1) the court did not err or abuse its discretion when it found the Facebook Messenger records to be authenticated under Me. R. Evid. 901; (2) assuming that the Facebook Messenger statements were hearsay, they were improperly admitted under Me. R. Evid. 803(3), but the error was harmless; and (3) there was sufficient evidence for the jury to find Defendant guilty of murder. View "State v. Tieman" on Justia Law

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The Supreme Judicial Court affirmed the order of the trial court imposing a discovery sanction following the State's failure to provide Defendant with a dash-cam video of Defendant allegedly committing the crime for which he was charged, holding that a serious sanction was warranted and that the court's choice of sanction was well within its discretion. Defendant was indicted for operating after revocation. Defendant subsequently sent the State a discovery request letter requesting any video or audio that would have been created as part of the stop that led to Defendant's arrest. Although the State had access to the arresting officer's dash-cam video of the stop, the State failed to turn over the video, arguing that it had no "evidentiary value." The trial court ultimately granted Defendant's request to suppress the evidence as a sanction for the State's discovery violation. The Supreme Judicial Court affirmed, holding that the court did not err in finding a discovery violation or abuse its discretion in selecting a sanction that effectively ended the prosecution. View "State v. Reed-Hansen" 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 Appellant, holding that the facts as found by the court were sufficient to prove that Appellant's actions constituted criminal mischief, which constitutes an act of harassment. In entering the order of protection from harassment against Appellant for one year the district court found that Appellant had committed three or more acts of harassment pursuant to Me. Rev. Stat. 5, 4651(2)(A). The Supreme Judicial Court affirmed, holding (1) the court erred in finding because there were three or more acts of harassment; but (2) the court's findings were sufficient to establish the elements of criminal mischief, which can stand alone as a single act of harassment. View "Allen v. Rae" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court in favor of the State on the State's complaint against Defendants for fraudulent transfer pursuant to Me. Rev. Stat. 14, 3575(1)(A), holding that the State's complaint was timely filed and that the court's findings were supported by competent evidence in the record. On appeal, Defendants argued that the State's action was barred by Me. Rev. Stat. 14, 3580(1). Under that statute, a cause of action with respect to a fraudulent transfer is extinguished unless brought within six years after the transfer or, if later, within one year after the transfer was or reasonably could have been discovered. The superior court determined that Defendants were equitably estopped from asserting the bar set out in section 3580(1) as an affirmative defense. The Supreme Judicial Court held (1) section 3580 is a statute of repose that has displaced the common law doctrine of estoppel on which the court relied in rejecting Defendants' section 3580(1) defense; but (2) the court's factual findings applied to trigger the one-year discovery exception to the six-year limitation provided in the statute. View "State v. Tucci" on Justia Law

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The Supreme Judicial Court vacated the order of the trial court suppressing evidence obtained during a traffic stop, holding that the motion court erred in restricting its legal analysis to certain evidence. The evidence suppressed in this case was obtained after a Maine State Police trooper stopped and ordered Defendant out of the motor vehicle she was driving so that he could administer field sobriety tests to her. The trial court concluded that the vehicle stop was valid but the subsequently investigatory seizure was not. The Supreme Judicial Court vacated the suppression order, holding that the motion court erred in restricting its analysis to evidence of the events and circumstances occurring at and prior to the moment that the trooper realized that the driver was not the person who was the subject to the complaint that led to the traffic stop. The Court then remanded the case for a determination as to whether the trooper's subsequent actions were reasonably related in scope to the purpose of the initial stop. View "State v. Bennett-Roberson" on Justia Law

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The Supreme Judicial Court vacated the judgment of the superior court denying in part and granting in part Appellant's petition for post-conviction relief as to his felony convictions, holding that the court erred by denying Appellant's petition despite its determination that Appellant had proved ineffective assistance of counsel for Appellant's misdemeanor charge. Appellant was convicted of both felony and misdemeanor counts. Appellant later filed a petition for post-conviction review, alleging ineffective assistance of counsel. The superior court found that Appellant had been denied his right to effective assistance of counsel by counsel's refusal to discuss Appellant's right to testify but concluded that trial counsel's actions prejudiced Appellant only with regard to Appellant's conviction for misdemeanor theft by unauthorized taking. The Supreme Judicial Court vacated the court's judgment and remanded the case, holding that, as a result of counsel's deficient performance, Appellant was prejudiced in his attempt to defend all charges brought against him, entitling him to post-conviction relief from his convictions on all counts. View "Ford v. State" on Justia Law