Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant for failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999), Me. Rev. Stat. 34-A, 11227(2), holding that, due to inadequate representation by Defendant's trial counsel, the court committed obvious error by not addressing the constitutionality of SORNA of 1999, as retroactively applied to Defendant.In 1990, Defendant was convicted of four counts of unlawful sexual contact, and in 1992, he was convicted of gross sexual assault. Neither offense required Defendant to register as a sex offender. After the Legislature enacted SORNA of 1999, Defendant 's two convictions became subject to SORNA of 1999. In 2018, Defendant was found guilty of failure to comply with a duty under SORNA of 1999. On appeal, Defendant argued that the retroactive application of SORNA of 1999 to require him to register for life violated the state and federal constitutional prohibitions against ex post facto laws. The Supreme Judicial Court agreed, holding that it could not be said beyond a reasonable doubt that the retroactive application of SORNA of 1999 to Defendant's 1990 and 1992 convictions did not affect his substantial rights by virtue of a punitive alteration of his original sentences. View "State v. Proctor" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs, holding that the the trial court did not commit obvious error in instructing the jury and did not abuse its discretion by denying Defendant's motion for a new trial.Specifically, the Supreme Judicial Court held (1) the trial court did not err in instructing the jury on accomplice liability; (2) the jury instruction on a written report not admitted into evidence was not erroneous; and (3) the court did not abuse its discretion by denying Defendant's motion for a new trial on the basis that statements made during the State's closing argument impermissibly commented upon Defendant's out-of-state residence as evidence of his guilt. View "State v. Plummer" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of one count of murder, holding that the trial court did not abuse its discretion by denying Defendant's motion for a new trial based on newly discovered evidence.Defendant's motion for a new trial was based on a statement allegedly made by his brother in the presence of another individual in which Defendant's brother claimed responsibility for the victim's murder. The trial court denied the motion. The Supreme Judicial Court affirmed, holding that the court did not abuse its discretion in determining that the brother's statement would not be admissible in a new trial and that, even if it were admissible, Defendant failed to establish that the proffered evidence would probably change the result if a new trial were granted. View "State v. Peaslee" on Justia Law

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The Supreme Judicial Court vacated Defendant's conviction for violating a condition of release, holding that the trial court lacked subject matter jurisdiction over Defendant's prosecution because the violation occurred in New Hampshire.Defendant was indicted for violating a condition of release. Defendant challenged the court's subject matter jurisdiction on the grounds that his alleged violation occurred outside Maine. The trial court determined that it had jurisdiction and found Defendant guilty. The Supreme Judicial Court vacated the judgment, holding that Maine lacked jurisdiction to prosecute Defendant on a charge of violating a condition of release for his conduct in New Hampshire. View "State v. Sloboda" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing or depraved indifference murder and gross sexual assault, holding that there was no error in the proceedings below.Specifically, the Court held (1) the trial court did not err by failing, sua sponte, to transfer venue based on the pretrial publicity about the case; (2) there was sufficient competent evidence on which a jury could reasonably find, beyond a reasonable doubt, that Defendant committed each element of both crimes; and (3) the trial court did not misapply any legal principles or abuse its discretion in imposing Defendant's sentence as to either crime. View "State v. Keene" on Justia Law

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The Supreme Judicial Court vacated the trial court's judgment on remand after Defendant successfully argued that his two convictions of felony murder and robbery violated his right to be free from double jeopardy, holding that the trial court erred by allowing the State to dismiss the robbery count on remand rather than merging it into the felony murder count.On remand, instead of the trial court merging the counts, the robbery count was dismissed by the State. The Supreme Judicial Court vacated the judgment, holding (1) when a trial results in multiple verdicts for the same offense, the appropriate procedure to prevent a double jeopardy violation is to merge, not dismiss, the duplicative counts; and (2) the trial court's failure to hold a new sentencing hearing on remand and conduct a new sentencing analysis pursuant to Me. Rev. Stat. 17-A, 1602 deprived Defendant of a substantial right. View "State v. Armstrong" on Justia Law

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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