Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's sentence imposed after he pled guilty to the intentional and knowing murder of his wife, holding that the sentencing court followed proper sentencing procedures and appropriately exercised its discretion in determining the sources and types of information to consider.After a sentencing hearing, the court sentenced Defendant to forty years in prison. Defendant appealed, arguing that the court misapplied the first step of the sentencing analysis required by Me. Rev. Stat. 17-A, 1252-C by failing to conduct a proper comparison of the circumstances of his crime to similar murders. The Supreme Judicial Court affirmed, holding (1) the court properly exercised its discretion in considering comparable sentences when imposing Defendant's sentence; and (2) the court thoughtfully considered the relevant facts and sentencing principles in determining Defendant's sentence. View "State v. Leng" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court sentencing Defendant to fifteen years of imprisonment after he was convicted by a jury of two counts of aggravated trafficking in scheduled drugs and one count of criminal forfeiture, holding that the sentencing court did not improperly engage in "double counting."On appeal, Defendant argued that the trial court erred when it considered the commercial motive of his offenses both when it set the basic sentence and when it set the maximum sentence. The Supreme Judicial Court affirmed, holding that the trial court properly considered different aspects of the commercial nature of the offense at each step of the court's analysis. View "State v. Plummer" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of intentional, knowing, or depraved indifference murder, one count of depraved indifference murder, and one count of arson and sentence of two life terms for the murders, holding that there was no error in Defendant's sentence.The trial court set Defendant's basic sentence for both murders at life imprisonment based on the application of two of the aggravating circumstances named in State v. Shortsleeves, 580 A.2d 145 (Me. 1990) - premeditation-in-fact and extreme cruelty. On appeal, Defendant challenged both aggravating circumstances. The Supreme Judicial Court affirmed, holding (1) the court did not err by applying premeditation-in-fact and extreme cruelty as aggravating circumstances to justify imposition of a basic sentence of life imprisonment for both counts of murder; and (2) the trial court precisely complied with the legal principles that apply to setting the basic sentence. View "State v. De St. Croix" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of domestic violence assault, holding that Defendant was not prejudiced.On appeal, Defendant argued (1) the trial court erred by allowing testimony from Defendant's fifteen-year-old daughter concerning Defendant's parenting practices, and (2) the State committed prosecutorial misconduct by commenting on admissible evidence during its cross-examination of her. The Supreme Judicial Court affirmed, holding (1) because, in her opening statement, Defendant indicated her pursuit of the parental discipline justification found at Me. Rev. Stat. 17-A, 106(1), the court did not err in admitting evidence of Defendant's parenting; and (2) the State committed prosecutorial conduct by eliciting and commenting on evidence that other children had been removed from Defendant's home, but the error was not so prejudicial that it affected the outcome of the proceeding. View "State v. Pratt" on Justia Law

The Supreme Judicial Court affirmed the interlocutory order of the superior court denying Defendant's motion to dismiss on double jeopardy grounds a superseding indictment against him, holding that neither the United States Double Jeopardy Clause nor its counterpart in the Maine Constitution barred the State from retrying Defendant on the superseding indictment.On appeal, Defendant argued that the superior court erred in denying his motion to dismiss because the dismissal of the original indictment against him after the jury was empaneled and sworn barred the State from charging him twice with the same offense. The Supreme Judicial Court clarified the implications of a defective indictment for purposes of the Double Jeopardy Clauses of the state and federal Constitutions and affirmed, holding (1) jeopardy attached in Defendant's trial; but (2) the trial court's dismissal of the indictment was not the equivalent of an acquittal and did not bar retrial. View "State v. Shirey" on Justia Law

In this action brought by Plaintiff, an inmate, the Supreme Judicial Court vacated the portions of the superior court's judgment denying injunctive relief, restoring good-time credit for the period of Plaintiff's nondisciplinary segregation, and entering judgment for Defendants on Plaintiff's 42 U.S.C.S. 1983 claim, holding that restoration of Plaintiff's "good time" was not an available remedy through judicial review of the Department's disciplinary action against Plaintiff and that the Maine Constitution's mandate regarding separation of powers does not preclude an award of injunctive relief on a section 1983 claim against the Department of Corrections.Plaintiff filed a complaint seeking judicial review of a disciplinary decision of the Department and injunction for violations of his civil rights. The superior court vacated the disciplinary decision but concluded that it was prohibited from entering injunctive relief on the section 1983 claim. The court then restored good-time credit for the period of nondisciplinary segregation as a remedy for Plaintiff's Rule 80C claim and entered judgment for Defendants on the section 1983 claim. The Supreme Judicial Court vacated the judgment in part and remanded for the court to determine whether injunctive relief should be awarded, enter judgment in Plaintiff's favor on his section 1983 claim and ordered the restoration of good-time credit for the period of Plaintiff's nondisciplinary segregation as a remedy for the constitutional violations alleged in his section 1983 claim. View "Burr v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder, entered by the trial court following Defendant's guilty plea, holding that the trial court did not abuse its discretion in denying Defendant's motion to withdraw her guilty plea and did not abuse its discretion or misapply sentencing principles in sentencing Defendant.Specifically, the Supreme Judicial Court held (1) contrary to Defendant's asserting on appeal, the court did not abuse its discretion in concluding that Defendant understood the nature of the offense charged and voluntarily entered the plea, and therefore, the trial court did not err in denying Defendant's motion to withdraw her guilty plea; and (2) the trial court did not misapply sentencing principles in determining the basic period of incarceration. View "State v. Weyland" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder of a deputy sheriff, holding that there was no error, clear or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in permitting the State to introduce in-court demonstrations of the possible circumstances of the shooting and in allowing the demonstration to be presented to the jury over Defendant's Rule 403 objection; (2) the trial court did not err in partially denying Defendant's motion to suppress statements he made to detectives after his arrest; and (3) there was no error in the court's sentencing proceedings, and the court did not abuse its discretion in imposing a sentence of life imprisonment. View "State v. Williams" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of aggravated assault, domestic violence criminal threatening, and other offenses, holding that there was no error, obvious or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in admitting expert testimony regarding strangulation; (2) the trial court did not abuse its discretion in imposing consecutive sentences; and (3) the trial court did not err by considering Defendant's criminal history as an aggravating factor at sentencing. View "State v. Treadway" on Justia Law

The Supreme Judicial Court vacated the judgment of conviction for assault and violation of condition of release entered by the trial court after a jury trial, holding that the court erred in instructing the jury concerning the justification of defense of property set forth in Me. Rev. Stat. 17-A, 105.After a second trial, a jury found Defendant guilty of violating a condition of release. Defendant appealed, arguing that the trial court erred in instructing the jury concerning the justification of defense of property. The Supreme Court agreed and remanded the matter for a new trial, holding (1) the trial court's oral and written instructions concerning the statutory justification of defense of property was erroneous in more than one respect; and (2) the errors were highly prejudicial and constituted obvious error. View "State v. Lee" on Justia Law