Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

The Supreme Judicial Court affirmed the twelve-year concurrent sentences imposed on Defendant for three counts of aggravated trafficking in scheduled drugs months after the parties entered into a plea agreement involving the dismissal of other charges, holding that the trial court did not misapply sentencing principles or abuse its sentencing authority.Defendant was convicted of three counts of aggravated trafficking in scheduled drugs and was sentenced to twelve-year concurrent sentences. On appeal, Defendant argued that the trial court violated his due process rights by imposing the maximum sentences allowed by the plea agreement and disregarded sentencing factors when it refused to suspend a portion of Defendant's sentences and order probation. The Supreme Judicial Court affirmed, holding that the trial court did not abuse its discretion when it determined that concurrent, unsuspended twelve-year sentences with no period of probation were appropriate for the three aggravated trafficking convictions. View "State v. Gordon" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of possession of sexually explicit material, holding that the superior court did not err by denying Defendant's motion to suppress on the grounds that Defendant, despite his diagnosis of Autism Spectrum Disorder (ASD), was capable of voluntary consent.Defendant sought to suppress his statements to police regarding sexually explicit material depicting minors found on his electronic tablet and any evidence of sexually explicit materials depicting minors discovered as a result. The superior court denied Defendant's motion to suppress, concluding that Defendant had the capacity to and did voluntarily speak to the police and consent to the search of his tablet. The Supreme Judicial Court affirmed, holding that Defendant's ASD did not render his statements or the search of his tablet involuntary. View "State v. Glenn" on Justia Law

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