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 unified criminal docket denying Appellant's petition for post-conviction review, holding that Appellant was deprived of the effective assistance of counsel when his trial attorney played a video of the ten-year-old victim's interview with police and that Appellant was adversely affected. Appellant was convicted of two counts of gross sexual assault, one count of unlawful sexual contact, and one count of visual sexual aggression against a child. The Supreme Court affirmed. Appellant later filed a petition for post-conviction review claiming that his trial attorney's representation was deficient because introducing the videotaped recording of the victim's entire interview with law enforcement was unnecessary to provide evidence supporting the victim's potential motive to fabricate the allegations. The post-conviction court denied denied the petition. The Supreme Court vacated the judgment below, holding that trial counsel's conduct was deficient and that counsel's actions rose to the level of comprising the reliability of Appellant's conviction and undermining confidence in it. View "Watson v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions of theft by unauthorized taking, theft by deception, securities violations, tax evasion, and failure to pay state income tax, holding that the trial court did not commit prejudicial error or abuse its discretion. Specifically, the Supreme Judicial Court held (1) the court did not abuse its discretion by admitting into evidence employee procedure manuals or certain checks with their memo lines unredacted without a limiting instruction; (2) the court did not err by declining to instruct the jury on the definition of the word “conduct,” by declining to instruct the jury on methods for calculating income taxes, and by failing to provide the jury with relevant statutes; and (3) the court did not err in concluding that Defendant's conduct satisfied the territorial applicability requirement of Maine law. View "State v. Lindell" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction and sentence for two counts of unlawful sexual contact, holding that sufficient evidence supported the conviction and that there was no error or abuse of discretion in the proceedings below. After a jury trial, Defendant was found guilty of two counts of unlawful sexual contact (Class B). Defendant was sentenced to ten years' imprisonment on the first count and a consecutive term of ten years, suspended, with five years of probation on the second count. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence to support the convictions; (2) the prosecutor's use of leading questions during the direct examination of the child victim did not violate Defendant's right to a fair trial; (3) testimony by the victim's mother did not violate the first complaint rule; and (4) the sentences imposed were not excessive or disproportionate, and the trial court did not abuse its discretion in imposing consecutive sentences. View "State v. Hansen" on Justia Law

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The Supreme Judicial Court dismissed as moot Appellant's appeal from a judgment entered by the superior court ordering the involuntary medical treatment of Appellant, holding that because Appellant was no longer subject to the court's involuntary treatment order, this appeal was moot. Appellant was arrested and charged with burglary and theft by unauthorized taking. While Appellant was in preconviction detention at the mental health unit of the Maine State Prison (MSP) the Department of Corrections filed an application pursuant to Me. Rev. Stat. 34-A, 3049 seeking the involuntary medication of Appellant. The court entered an ex parte order granting the emergency application and permitting the immediate medication of Appellant for a period of 120 days. Appellant appealed. The Supreme Judicial Court dismissed the appeal as moot, holding that because Appellant was no longer at the mental health unit of the MSP and the involuntary treatment order had expired, the appeal was moot and no exceptions to the mootness doctrine applied. View "In re Involuntary Treatment of K." on Justia Law

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The Supreme Judicial court vacated the judgment of the trial court denying Defendant's petition for post-conviction review, holding that Defendant must receive a new hearing on his petition. Defendant pleaded guilty of trafficking in prison contraband. Defendant later filed a petition for post-conviction review alleging ineffective assistance by his plea counsel. The court held a hearing and announced that it would grant Defendant's petition. The court began to issue that decision from the bench, but an interruption led the court to resume the hearing. The court then proceeded to deny the petition. The Supreme Court reversed, holding that, under the circumstances of this case, the process at Defendant's hearing irredeemably tarnished the appearance of fairness in the proceeding. View "Evans v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for unlawful sexual contact and domestic violence assault, holding that the prosecutor did not commit misconduct and that the trial court did not abuse its discretion in denying Defendant the opportunity to call as a witness the district attorney's victim witness advocate (VWA). On appeal, Defendant argued that the prosecutor committed multiple instances of misconduct and that the trial court abused its discretion in denying him the opportunity to call the VWA to testify. The Supreme Judicial Court affirmed, holding (1) even if a statement made by the prosecutor was improper, it did not amount to harmful error; (2) the trial court did not abuse its discretion when it denied Defendant's motion for a new trial; and (3) the trial court did not abuse its discretion in denying Defendant's request that the VWA testify. View "State v. Sholes" on Justia Law

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The Supreme Judicial Court affirmed in part and vacated in part Defendant's judgment of conviction of gross sexual assault, unlawful sexual contact, sexual abuse of a minor, and unlawful sexual touching, holding that there was insufficient evidence to support the convictions of gross sexual assault and unlawful sexual contact. The Supreme Judicial Court remanded the case for resentencing, holding (1) there was sufficient evidence to support Defendant's convictions for sexual abuse of a minor and unlawful sexual touching; and (2) because the State did not present any evidence that Defendant, a substitute teacher, possessed the requisite authority over the victim, a student, at the time that he committed the sexual act and sexual contact, there was insufficient evidence to convict Defendant of gross sexual assault and unlawful sexual contact. View "State v. Conroy" on Justia Law

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The Supreme Judicial Court affirmed Defendant's judgment of conviction of two counts of stalking and two counts of harassment entered by the trial court after a jury trial, holding that the court did not err or abuse its discretion. Specifically, the Court held (1) the trial court did not violate Defendant's right to a fair trial; (2) the judgment entered in Defendant's favor in a prior protection from harassment matter was not entitled to res judicator effect in this criminal prosecution; (3) the trial court did not err when it allowed one of the victims to testify that a lawsuit Defendant filed against the victim was dismissed with prejudice; (4) the trial court did not err in denying Defendant's motions for judgment of acquittal; and (5) the trial court committed no obvious error in failing to give three jury instructions. View "State v. Williams" on Justia Law

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The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court as a result of a jury verdict finding Defendant guilty of two counts of manslaughter, two counts of causing a death while operating under the influence, and related charges, holding that the court did not err when it denied Defendant's motion to suppress the results of a warrantless blood draw taken at the scene of a fatal motor vehicle accident. Me. Rev. Stat. 29-A, 2522(2) directs law enforcement officers to test the blood of all drivers involved in a fatal, or likely fatal, motor vehicle accident without any requirement of probable cause before the blood draw. Defendant argued on appeal that the statute is unconstitutional on its face. The Supreme Judicial Court agreed but nonetheless affirmed the trial court's denial of Defendant's motion to suppress, holding (1) Me. Rev. Stat. 29-A, 2522(2) violates the Fourth Amendment because it does not require that law enforcement have consent or probable cause to believe that a driver is impaired before drawing a person's blood; but (2) the trial court correctly denied Defendant's motion to suppress because the "good faith" exception to the exclusionary rule applied to the search. View "State v. Weddle" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of gross sexual assault, holding that the evidence was sufficient to support the trial court's finding that Defendant possessed the requisite mens rea. On appeal, Defendant argued that Me. Rev. Stat. 17-A, 253(2)(M) must be read to require proof that he knew that the person with whom he was engaging in a sexual act had not expressly or impliedly acquiesced to the sexual act and that the evidence was insufficient to support a finding that he knew the victim had not expressly or impliedly acquiesced to the sexual activity. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support a finding that Defendant engaged in a sexual act that he knew the victim had not expressly or impliedly acquiesced to. View "State v. Asaad" on Justia Law