Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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In this case, Jacob R. Labbe Sr. was convicted by the trial court on one count of domestic violence stalking and two counts of violation of a protective order. Labbe appealed arguing that the stalking statute was unconstitutionally vague, the evidence was insufficient to convict him of domestic violence stalking, the court erred in denying his request to dismiss the charges as de minimis, and the court made several erroneous evidentiary rulings.The Maine Supreme Judicial Court affirmed the conviction. It held that the stalking statute was not unconstitutionally vague. The court found that the statute provided a clear definition of "course of conduct" and enough evidence supported a conviction for domestic violence stalking. It further held that the court did not abuse its discretion in denying Labbe's request to dismiss the charges as de minimis. The court also found no error in the trial court's evidentiary rulings. The court concluded that the First Amendment did not require the State to prove reckless disregard on the part of Labbe for the effect of his statements on the victim, as the charge was not based on the content of Labbe's communications but rather on his persistent unwelcome contact with the victim. Therefore, the court found no error in the trial court's instructions to the jury. The conviction was affirmed. View "State v. Labbe" on Justia Law

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The Supreme Judicial Court of Maine upheld the conviction of Ralph A. Tripp Jr., who was found guilty of several drug-trafficking offenses, possession of a firearm by a prohibited person, and criminal forfeiture of property. Tripp appealed on the grounds that he should be immune from prosecution for his drug-related offenses, that there were errors in the State's conduct during its opening statement and closing argument, and that the jury was not provided with clear instructions. The court ruled that Maine’s immunity statutes did not apply in this case, that any prosecutorial error did not affect Tripp’s substantial rights, and that the trial court sufficiently corrected any potential confusion stemming from its initial jury instructions. The court therefore affirmed the judgment. The case involved Tripp and his wife, Amanda Tripp, who resided in a rooming house in Bangor. After the Tripps moved in, residents noticed an increase in visitors, found hypodermic needles outside the building, and frequently observed the Tripps letting visitors into the building. On one occasion, Tripp called 9-1-1 to report a person unconscious in one of the shared bathrooms of the rooming house. The person was later pronounced dead, and the cause of death was determined to be acute intoxication from multiple drugs. When the police executed a search warrant for Tripp’s room, they seized a handgun, various drugs, drug paraphernalia, and cash. Tripp was subsequently charged with several offenses. View "State v. Tripp" on Justia Law

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Mario Gordon appealed a judgment that denied his petition for post-conviction review in which he alleged ineffective assistance of counsel. In the underlying case, Gordon had pleaded guilty to multiple charges pursuant to a plea agreement with a sentencing cap. This was based on his attorney's advice that Gordon would likely receive a sentence significantly more lenient than the one the court ultimately imposed. Gordon's attorney had advised him that if he agreed to a twelve-year cap, the sentence would likely be eight years without suspension or ten years with a portion of the sentence suspended. However, the court imposed a sentence of twelve years without suspension, leading Gordon to argue that he had received ineffective assistance of counsel.The Maine Supreme Judicial Court held that Gordon's counsel did not provide ineffective assistance. The Court found that the attorney's advice was a strategic decision that was not "manifestly unreasonable," as Gordon was aware that he could receive up to a twelve-year sentence but chose to proceed with the twelve-year cap option in hopes of obtaining probation. The Court also found that Gordon could not demonstrate that his plea was involuntary as he was informed during the plea colloquy that he could be sentenced to up to twelve years. Furthermore, the Court found that Gordon's attorney was not required to object to the sentence when it was imposed, as Gordon had acknowledged that he understood the terms of his plea agreement. Therefore, the Court affirmed the judgment denying Gordon's post-conviction review petition. View "Gordon v. State" on Justia Law

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In the State of Maine v. Dale F. Thistle, the Maine Supreme Judicial Court upheld the conviction of Dale Thistle, an attorney, for theft by misapplication of property. Thistle was hired by Donna Friend, personal representative of the estate of Gilman Friend, to explore a potential wrongful death suit against emergency responders. Thistle negotiated a settlement of $390,000, which he deposited into his Interest on Lawyer’s Trust Account (IOLTA). Thistle then misappropriated the funds, failing to distribute the owed amount to Gilman's children, and instead frequently withdrawing money for personal expenses.Thistle appealed his conviction on several grounds, including that the trial court erred by not granting his motion for acquittal due to a statute of limitations defense, the court erred in its instructions to the jury on the Maine Rules of Professional Conduct, the State committed prosecutorial error, and that the evidence was insufficient to convict him.The Supreme Judicial Court rejected all of Thistle's arguments. The court found that Thistle had waived his statute of limitations defense by admitting facts that tolled the limitations period. The court also held that the prosecutor's statements during closing arguments did not constitute error. Finally, the court ruled that there was sufficient evidence to support the jury's finding that Thistle intentionally or recklessly failed to pay the settlement funds to Gilman's children and used the money as his own, thereby committing theft by misapplication of property. View "State v. Thistle" on Justia Law

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In the case before the Maine Supreme Judicial Court, Dana A. Healey appealed his conviction for domestic violence assault. Healey argued that the trial court exceeded its discretion by not allowing him or his attorneys to conduct a voir dire examination of the jury and by denying his requests to cross-examine the victim about her recanted domestic violence allegation against another person and the text messages that she sent to Healey after his arrest. Healey contended that these rulings violated his constitutional rights to a jury trial and to confront witnesses against him.The court acknowledged Healey's concerns but ultimately affirmed the trial court's decision. The court found that the trial court did not abuse its discretion when it denied Healey’s request to cross-examine the victim about her recanting a domestic violence allegation against another person. The court also found that the trial court erred in excluding at least one of the victim’s text messages to Healey: the message stating, “We’re even.” However, the court determined that, despite this error, there was sufficient, independent evidence to support the jury's verdict.The court based its decision on the testimony of the responding officer and a witness who saw the incident, as well as the 9-1-1 call made by the witness. These pieces of evidence, the court concluded, provided sufficient support for the jury's verdict, regardless of the excluded text messages. Therefore, the court was satisfied beyond a reasonable doubt that the excluded evidence would not have affected the jury's verdict. As such, the court affirmed Healey's conviction and sentence. View "State of Maine v. Dana A. Healey" on Justia Law

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In the case before the Maine Supreme Judicial Court, Taylor A. Pelletier was convicted of multiple crimes, including two counts of kidnapping with a dangerous weapon, two counts of aggravated assault, one count of domestic violence threatening with a dangerous weapon, and one count of domestic violence terrorizing with a dangerous weapon. The trial court found Pelletier guilty based on evidence from a home security system and the victim's testimony, which the court found credible.Pelletier appealed his conviction, raising three main issues: the sufficiency of the evidence supporting his kidnapping conviction, the sufficiency of the indictment for the first count of kidnapping, and the trial court's denial of his motion to dismiss for alleged discovery and Brady violations.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court found that the evidence was sufficient to support the kidnapping conviction. The court held that Pelletier had confined the victim inside the house for a substantial period, which went beyond the time necessary to commit the assaults. The court also found that the indictment adequately stated the charges against Pelletier, giving him sufficient notice to prepare his defense. Lastly, the court held that the trial court did not abuse its discretion in denying Pelletier's motion to dismiss for discovery and Brady violations. The court held that the trial court's sanction of a continuance was sufficient to mitigate any prejudice caused by the State's late disclosure of evidence. View "Maine v. Pelletier" on Justia Law

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The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court for attempted murder and other crimes with respect to Defendant's contended errors but vacated Defendant's sentences with respect to domestic violence assault and domestic violence terrorizing, holding that those sentences exceeded the maximum allowable under Me. Rev. Stat. 17-A, 1604(1)(D).On appeal, Defendant argued that the trial court abused its discretion by imposing a discovery sanction under M.R.U. Crim. P. 16(e) and that the jury venire was not drawn from a fair cross-section of the community. The Supreme Judicial Court affirmed the convictions but vacated the sentences in part, holding (1) the trial court's discovery sanction constituted a fundamentally fair balance between the parties' competing interests; (2) Defendant did not sufficiently preserve or present a sufficient record for the Supreme Court to reach Defendant's second contention; and (3) the trial court erred by entering a one-year sentence for Defendant's convictions for domestic violence assault and domestic violence, both class D misdemeanors. View "State v. Page" on Justia Law

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The Court of Appeals affirmed the judgment of default and forfeiture of $17,815 in cash bail entered after the trial court denied Defendant's motion to set aside the forfeiture of that portion of his deposited cash bail, holding that the trial court did not abuse its discretion in denying Defendant's motion to set aside the forfeiture.On appeal, Defendant argued that the trial court abused its discretion in denying his motion because the bail bond did not explicitly warn him of forfeiture as a potential consequence for violating the condition of his release that he commit no violation of a bail condition. The Court of Appeals affirmed, holding that, on the record, the trial court did not abuse its discretion in denying Defendant's motion as to $17,815 of his deposited cash bail. View "State v. Covington" on Justia Law

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The Supreme Judicial Court affirmed in all respects a judgment of conviction of two counts of murder and other weapons-related counts entered by the trial court following a jury trial on the murder charges and a bench trial on the other charges, holding that there was no error or abuse of discretion.Specifically, the Supreme Judicial Court held that the trial court (1) did not err by denying Defendant's request to present evidence to the jury that a State investigator had monitored telephone calls between Defendant and his attorney while Defendant was in pretrial detention; (2) did not err by giving a jury instruction on accomplice liability; (3) did not err by not granting a mistrial based on certain comments made by the prosecutor during the State's closing arguments; and (4) did not err in sentencing Defendant to life sentences on the murder charges. View "State v. Nightingale" on Justia Law

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The Supreme Judicial Court affirmed the judgment of conviction of hindering apprehension or prosecution entered by the trial court following a jury trial, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not commit obvious error in allowing a closing argument implying that Appellant had a burden of proving that the State's witnesses had a motive to lie and instructing the jury that it could "consider whether there has been any evidence introduced of any motive or lack of motive for a witness to exaggerate or lie"; and (2) the trial court did not abuse its discretion in denying Appellant's motion for voir dire of jurors filed after learning that one witness said “good luck” to the jurors while leaving the courtroom. View "State v. Lipscombe" on Justia Law