Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating a vehicle when the registration of that vehicle was suspended, holding that the State was not required to provide counsel to Defendant. Defendant was tried before a jury without counsel. The jury returned a verdict of guilty, and the trial court entered a judgment after imposing a fine supplemented by surcharges. Defendant appealed, arguing that he had a right to court-appointed counsel because of his inability or unwillingness to pay a fine and that jury selection proceedings were deficient. The Supreme Judicial Court affirmed, holding (1) because Defendant was not at risk of incarceration as part of the sentence the State was not required to provide counsel; and (2) there was no basis for a claim of legal error or abuse of discretion regarding jury proceedings. View "State v. Lipski" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of conviction of burglary entered by the trial court after a jury trial, holding that the trial court did not err in admitting recordings of incriminating telephone conversations that Defendant had with his girlfriend while he was in jail. A jury found Defendant guilty of burglary. The court sentenced Defendant to one year in prison, with all but sixty days suspended, and a one-year term of probation. On appeal, Defendant primarily challenged the adequacy of the foundation that the State provided to establish the authenticity of the jail recordings. The Supreme Judicial Court affirmed, holding that there was no evidence of tampering and that the court did not err in finding a sufficient foundation for the recordings' admissibility. View "State v. Coston" on Justia Law

by
The Supreme Judicial Court vacated in part the order of the superior court granting Defendant's motion to suppress evidence obtained pursuant to a search warrant for Defendant's cell phone account data and a search warrant for a codefendant's cell phone data, holding that there was no illegality in the search of Defendant's data and that Defendant lacked standing to challenge the search of the codefendant's data. On appeal, the State argued that Defendant lacked standing to challenge the warrant issued to search the codefendant's account data and that the superior court erred by determining that neither search warrant was supported by probable cause. The Supreme Judicial Court vacated the order to the extent that it suppressed the evidence obtained through the two warrants, holding (1) the affidavit for the warrant to search Defendant's account data was supported by probable cause; and (2) given that Defendant failed to assert any reasonable expectation of privacy in the codefendant's account data, Defendant lacked standing to challenge the warrant to search the codefendant's data. View "State v. Warner" on Justia Law

by
The Supreme Judicial Court vacated the judgment entered by the trial court convicting Defendant of unlawful sexual touching and assault, holding that the court erred in allowing the State to introduce improper character evidence and that the prejudice suffered as a result of that error, when considered cumulatively with the effect of an instance of prosecutorial misconduct, deprived Defendant of a fair trial. Although the issue was not preserved at trial or raised on appeal, the Supreme Judicial Court examined the State's cross-examination of Defendant to determine whether prosecutorial misconduct occurred. The Supreme Judicial Court remanded the case for a new trial, holding (1) on the record, prosecutorial misconduct plainly occurred, and the misconduct affected Defendant's substantial rights; (2) the introduction into evidence of federal probation violations was error and highly prejudicial to Defendant; and (3) the cumulative effect of the trial errors deprived Defendant of a fair trial. View "State v. Robbins" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the unified criminal docket convicting Defendant of unlawful sexual contact, holding that the trial court did not err when it admitted in evidence as past recollection recorded a video recording in which the victim described Defendant's assaults of her. The video recording was of a forensic interview conducted of the victim shortly after the crime occurred. On appeal, Defendant argued that the court erred in admitting the video in evidence because the State had not established the proper foundation required by the exception to the hearsay rule and because the admission of the video violated his constitutional right to confront the witness. The Supreme Judicial Court disagreed, holding (1) the court did not err by determining that the State had satisfied the foundational elements of the recorded recollection exception to the hearsay rule; and (2) the court did not violate Defendant's constitutional right to confrontation by admitting the evidence because Defendant was provided the opportunity to cross-examine the victim about her out-of-court statements. View "State v. Adams" on Justia Law

by
The Supreme Judicial Court Defendant's conviction of multiple sex crimes, holding that the trial court did not err in the jury selection process when it denied Defendant's motion to strike one of the jurors for cause and when it denied Defendant's motion to strike the entire venire after one prospective juror left the courtroom in an agitated state. At the beginning of jury selection, one prospective juror abruptly left the room when the charges against Defendant were being described. The court asked the remaining pool of jurors if there was anyone who would have difficulty being fair and impartial going forward, and thirty-four potential jurors answered in the affirmative. Defendant filed a motion to strike the entire jury venire. The court denied the motion, instead striking the thirty-four potential jurors. Defendant later moved to strike one juror on the ground that he had been equivocal about his ability to remain fair and impartial. The Supreme Judicial Court denied the motion. The Supreme Judicial Court affirmed, holding that the circumstances of this case did not present an extraordinary situation in which prejudice may be presumed or bias implied and that the court did not err in determining that the individual juror's ability to be fair and impartial was not affected. View "State v. Carey" on Justia Law

by
The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of operating under the influence, holding that the trial court erred by admitting, as an adoptive admission and over Defendant's objection, the inculpatory statement of Defendant's friend, who did not testify at trial. The court admitted the friend's statement as an admission adopted by Defendant, ruling that the statement was admissible as an opposing party's statement. The friend was not present at trial and did not testify. The Supreme Judicial Court reversed, holding (1) under these circumstances, the defendant must undertake an observable action, either through words or conduct, by which a reasonable person would understand that the defendant did, in fact, adopt the statement; (2) although a statement may be admissible as an admission of a party in a civil case if the statement would, in context, caller a reply, this standard does not apply in a criminal trial because of a defendant's constitutionally protected right to remain silent; and (3) Defendant's silence in this case could not be construed as an adoption of the friend's statement. The Court then remanded the case for further proceedings. View "State v. Rutherford" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated assault, assault, and attempted kidnapping with the intent to hold for ransom or reward, holding that the court did not err in its instructions to the jury and that there was sufficient evidence to support the convictions. Specifically, the Court held (1) there was sufficient evidence for the jury to have found beyond a reasonable doubt that Defendant was guilty of the convictions; and (2) the court did not err in denying Defendant's requested instructions regarding the meaning of physical health and the use of a dangerous weapon. The Court remanded the case only for dismissal of a fourth count on which the parties intended a dismissal after the court declared a mistrial. View "State v. Hall" on Justia Law

by
The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of murder but finding him guilty of felony murder and robbery in connection with a drug-related homicide, holding that Defendant's conviction for both felony murder and the underlying felony of robbery violated the constitutional protection from double jeopardy. Specifically, the Court held (1) the trial court did not err, while exercising its gatekeeping function, by declining to admit certain hearsay statements because the admission of those statements would have run contrary to the truth-seeking function of Me. R. Evid. 804(b)(3); and (2) although Defendant did not raise the double jeopardy issue in the trial court, the State acknowledged that Defendant's convictions for both robbery and felony murder violated the double jeopardy clauses of the state and federal constitutions, and therefore, the case must be remanded for further post-trial proceedings to eliminate the double jeopardy effect arising from the two charges. View "State v. Armstrong" on Justia Law

by
The Supreme Judicial Court affirmed Defendant's conviction and sentence for murder, holding that that trial court erred by excluding evidence of Defendant's guilty plea to the murder charge but that the error was harmless. Specifically, the Supreme Judicial Court held (1) the court erred by excluding certain evidence purporting to show that Defendant's friend was responsible for the murder, including evidence that Defendant's friend had pleaded guilty to murdering the same victim, but the error was harmless because of the magnitude and strength of the State's evidence; and (2) the sentence of sixty-five years in prison was constitutional and did not violate either the Eighth Amendment to the United States Constitution or Me. Const. art. I, 9, and the sentence was proportionate, even for someone who, like Defendant, was eighteen years old when he was arrested. View "State v. Dobbins" on Justia Law