Justia Criminal Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court vacated Defendant's conviction for intentional or knowing murder entered in the trial court following a jury trial, holding that the trial court erred in denying Defendant's motion to suppress evidence and statements that were obtained in violation of Defendant's constitutional rights.In denying Defendant's motion to suppress, the trial court determined that the searches of Defendant's property were not unreasonable because the emergency aid doctrine supported the searches, that suppression would not be justified even if they were, and that Defendant's statements were made voluntarily. The Supreme Judicial Court vacated the judgment of conviction, holding that Defendant's rights under the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution and Me. Const. art. I, 6, 6-A were violated, and that the trial court erred in denying Defendant's motion to suppress. View "State v. Akers" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court accepting Defendant's conditional guilty plea to escape, holding that, by separately trying Defendant for criminal threatening in Sagadahoc County and then for escape in Kennebec County, the State violated Me. Rev. Stat. 17-A, 14.Defendant was arrested for criminal threatening with a dangerous weapon shortly after he allegedly left the custody of a psychiatric center without permission. A jury acquitted Defendant of the criminal threatening charge in Sagadahoc County. Thereafter, the State charged Defendant with escape in Kennebec County. Defendant entered a conditional guilty plea to the charge and then appealed. The Supreme Judicial Court vacated the trial court's judgment, holding (1) Sagadahoc County was a proper venue to prosecute Defendant for escape because it was the county in which he was apprehended; and (2) the trial court's finding that Defendant's alleged threat against a family member arose from the same criminal episode was supported by the record. View "State v. Gessner" on Justia Law

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The Supreme Judicial Court affirmed Defendant's sentence of forty years' imprisonment imposed in connection with his guilty plea to murder, holding that the trial court did not misapply any principle or abuse its discretion in its sentencing analysis or in its exercise of its sentencing power.Defendant pleaded guilty of intentional or knowing murder. Based on its findings and consideration of sentences imposed in comparable cases, the trial court set the basic sentence at fifty to fifty-five years' imprisonment. After weighing the aggravating and mitigating factors, the court set the final sentence of forty years' imprisonment. The Supreme Judicial Court affirmed the sentence, holding that although the court was not required to consider comparable cases, the court correctly applied sentencing principles at both steps of the sentencing analysis. View "State v. Bentley" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction and sentence for knowing or intentional murder and the denial of his motion for a new trial, holding that there was no error.On appeal, Defendant argued that the trial court erred or abused its discretion in excluding alternative-suspect evidence, failing to provide an adequate explanation in setting the basic sentence, and denying his motion for a new trial based on a juror's statements made after Defendant's conviction. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion in excluding alternative-suspect evidence as insufficient to establish a reasonable connection to the crime; (2) the court did not misapply sentencing principles in setting a basic sentence of forty to forty-five years' incarceration; and (3) the court did not err or abuse its discretion in denying Defendant's motion for a new trial. View "State v. Daly" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court finding Defendant guilty of manslaughter, holding that there was no error in the proceedings below.Defendant was indicted for intentional or knowing murder. After a bench trial, the trial court found him guilty of the lesser included offense of manslaughter. The Supreme Court affirmed, holding (1) the State disproved beyond a reasonable doubt one of Defendant's self-defense justification; and (2) Defendant expressly waived his argument that the trial court erred in failing to analyze another of Defendant's self-defense justifications under Me. Rev. Stat. 17-A, 108(2)(A). View "State v. Cardilli" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for intentional or knowing murder and sentence of forty years' imprisonment, holding that there was no error in the proceedings below.Specifically, the Supreme Judicial Court held that the trial court (1) did not err in determining that Defendant had waived the religious privilege in relation to a communication he made to church leaders; (2) did not err by declining to give Defendant's requested jury instruction that the State was required to prove that he intentionally or knowingly killed the victim and not just intentionally or knowingly killed another human being; (3) did not err when it denied Defendant's motion to continue the sentencing hearing; and (4) misapplied no legal principles and acted within its discretion in sentencing Defendant. View "State v. Gaston" on Justia Law

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The Supreme Judicial Court vacated the judgment entered by the superior court denying in part Petitioner's petition for post-conviction review of his conviction on several sexual assault charges, holding that Petitioner was deprived of his right to the effective assistance of trial counsel.After a trial, the jury found Petitioner guilty of one count each of gross sexual assault, unlawful sexual contact, and sexual abuse of a minor. The Supreme Court affirmed. Petitioner subsequently filed a postconviction petition arguing that he had been deprived of his right to the effective assistance of counsel. The Supreme Court granted the petition as to the convictions for unlawful sexual contact and sexual abuse of a minor and vacated Petitioner's convictions on those counts but denied Petitioner's petition as to the conviction for gross sexual assault. The Supreme Judicial Court vacated the judgment and remanded for entry of a judgment granting Petitioner's petition for post-conviction review and vacating the remaining conviction, holding that counsel's performance was deficient and that Petitioner was entitled to post-conviction relief from the remaining portion of the judgment of conviction. View "Hodgdon v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of the depraved indifference murder of her daughter and sentence of forty-eight years in prison, holding that Defendant's claims of error were unavailing.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress the statements she made to investigators on the day of and the day after her daughter's death; (2) the trial court did not abuse its discretion by denying Defendant's request for a mistrial; (3) the court did not err by declining Defendant's requests for jury instructions regarding accomplice liability and duress; and (4) the court acted within its discretion in arriving at Defendant's sentence. View "State v. Carrillo" on Justia Law

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The Supreme Judicial Court affirmed the dispositional order imposed after an adjudication that juvenile Timothy Silva committed manslaughter, holding that the court did not err in committing him to detention.Silva was sixteen years old when he lost control of a vehicle and caused the death of three passengers and serious injuries to a fourth. The juvenile court adjudicated Silva to have committed one count of manslaughter and committed him to Long Creek Youth Development Center for an undetermined period of up Silva's twenty-first birthday. The Supreme Judicial Court affirmed, holding that the court's disposition was neither error nor an abuse of discretion. View "State v. Silva" on Justia Law

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The Supreme Judicial Court affirmed Defendant's judgment of conviction for intentional or knowing murder, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that the trial court erred in refusing to give a jury instruction on the affirmative defense of adequate provocation, erroneously denied his motion to suppress multiple confessions, and abuse its discretion in denying his motion to recuse the presiding justice. The Supreme Judicial Court affirmed, holding that the trial court (1) correctly determined that the jury instruction for adequate provocation was not generated by the evidence; (2) did not err in determining that the statements Defendant sought to suppress were voluntary; and (3) did not abuse its discretion by denying Defendant's motion to recuse. View "State v. Clark" on Justia Law