Justia Criminal Law Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant's conviction of one count of Class B theft by deception and one count of Class C theft by deception, holding that there was no error in the proceedings below.On appeal, Defendant argued (1) the trial court erred by failing to include a “nexus” element in its instruction to the jury on the charge of theft by deception, (2) the evidence was insufficient to convict him of theft by deception, and (3) his actions constituted a breach of contract, not a criminal offense. The Supreme Judicial Court affirmed, holding (1) the jury rationally could have found beyond a reasonable doubt each element of theft by deception based on the testimonial and documentary evidence presented at trial and reasonable inferences drawn therefrom; (2) the evidence was sufficient to support the jury's verdict; and (3) Defendant waived his ability to challenge the jury instructions on appeal. View "State v. McLaughlin" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for manslaughter, holding that the evidence admitted at trial was sufficient to prove beyond a reasonable doubt that Defendant caused the child victim's death.Defendant was convicted of manslaughter for the death of a seven-month-old infant. The sentencing court sentenced Defendant to eleven years' imprisonment, with all but five years and six months suspended, and four years' probation. On appeal, Defendant challenged the sufficiency of the evidence. The Supreme Judicial Court affirmed, holding that the court was justified in finding beyond a reasonable doubt that Defendant, acting with criminal negligence, caused the child's death. View "State v. Mackin" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of five counts of unlawful sexual touching and one count of visual sexual aggression against a child, holding that Defendant received a fair trial with properly admitted expert testimony and a clear guilty verdict.After a third trial, Defendant was convicted and sentenced. On appeal, Defendant argued that the trial court erred in accepting the jury's verdict, that prosecutorial misconduct deprived him of a fair trial, and that the court erred in admitting the State's expert witness's testimony. The Supreme Judicial Court affirmed, holding that the court did not clearly err in finding the State's witness to be a qualified expert witness. View "State v. Westgate" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court terminating Defendant's deferred disposition and imposing sentence following his earlier guilty plea to trafficking in prison contraband, holding that the court did not err in admitting evidence at the termination hearing that had been suppressed in a separate criminal case.Defendant pleaded guilty to trafficking in prison contraband, and the court deferred disposition on that count. Defendant was subsequently indicted on new criminal charges. The court granted Defendant's motion to suppress evidence resulting from a police officer's search of his pocket on the basis that the search was unconstitutional. The State then dismissed the charges. In the first case, the State moved to terminate Defendant's deferred disposition based on his alleged new criminal conduct. Defendant sought an order continuing suppression of the evidence. The court denied Defendant's motion. The court then found that Defendant had violated the deferred disposition agreement and imposed sentence. The Supreme Judicial Court affirmed, holding that because the "sole purpose" of the exclusionary rule was satisfied by the exclusion of the evidence derived from the unlawful search in the dismissed criminal case, the trial court did not err in ruling that the suppressed evidence could be considered in the deferred disposition termination proceeding. View "State v. Hourdeh" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of depraved indifference murder pursuant to Me. Rev. Stat. 17-A, 201(1)(B), holding that the State presented sufficient evidence such that the fact-finder could have found each element proved beyond a reasonable doubt.Specifically, the Supreme Judicial Court held (1) the trial court did not err in finding Defendant guilty of murder because the State presented sufficient evidence to support the fact-finder's determination that the State had proved each element beyond a reasonable doubt; and (2) the trial court did not err or abuse its discretion when it limited Defendant's cross-examination of the State's Chief Medical Examiner. View "State v. Gatto" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for reckless conduct and aggravated criminal mischief, holding that the trial court did not abuse its discretion by offering Defendant a continuance of the trial in lieu of excluding his medical records.On appeal, Defendant argued that the trial court abused its discretion by denying his motion to suppress his personal medical records as a sanction for the State's late seizure of the records. The Supreme Judicial Court agreed that the State's conduct undermined the purpose of Maine Rule of Unified Criminal Procedure 18(b) but that the court's offer of a continuance in lieu of the exclusion of the evidence constituted an appropriate response to the State's conduct. View "State v. Mullen" on Justia Law

In this appeal from Defendant's conviction for eleven counts of gross sexual misconduct, the Supreme Judicial Court vacated the judgment of conviction on one count, vacated the dismissal of other counts and remanded for entry of a judgment of acquittal on those counts, and affirmed in all other respects, holding that Defendant's convictions on both Counts 5 and 30 violated his double jeopardy protections and that the court erred in allowing the State to dismiss Counts 27, 28, and 29 during trial without Defendant's consent.The indictment charged Defendant with fifteen counts (Counts 1-13, 30-31) of gross sexual misconduct against the victim and sixteen counts (Counts 14-29) of gross sexual misconduct against a second alleged victim. During trial, the court granted Defendant's motion for a judgment of acquittal on Counts 10-13, and the State dismissed Counts 27-29. Defendant was found guilty of Counts 1-9 and 30-31 and not guilty on the remaining counts. The court entered judgment in accordance with the verdict. The Supreme Judicial Court held that the trial court erred in failing to rule that the Double Jeopardy Clause barred convictions on both Counts 5 and 30 and allowing the State to dismiss Counts 27, 28, and 29 rather than entering a judgment of acquittal on those counts. View "State v. Paquin" on Justia Law

The Supreme Judicial Court affirmed the judgments of the trial court terminating Appellant's participation in the Co-Occurring Disorders and Veterans Court (Veterans Court), holding that the court did not err or abuse its discretion in terminating Appellant's participation in the Veterans Court.The Veterans Court is a criminal docket that provides judicial monitoring, specialized treatment, and other services for military veterans who have disorders often attributable to their military service. Appellant was charged with leaving the scene of an accident and three other offenses. Appellant was admitted to the Veterans Court. Agreeing to sentencing outcomes in a plea agreement and entering into a bail contract, Appellant pleaded guilty to all charges against him. The court later terminated Appellant's participation in the Veterans Court, finding that Appellant had violated the conditions of his bail contract. The Supreme Judicial Court affirmed, holding (1) this matter was properly before the Court; and (2) given Appellant's failure to comply with the requirements for participation in the treatment court and his violations of the agreements, his termination from the Veterans Court was warranted. View "State v. Catruch" on Justia Law

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