Justia Criminal Law Opinion Summaries

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

The Supreme Judicial Court affirmed Defendant's convictions of theft by unauthorized taking, theft by deception, securities violations, tax evasion, and failure to pay state income tax, holding that the trial court did not commit prejudicial error or abuse its discretion.Specifically, the Supreme Judicial Court held (1) the court did not abuse its discretion by admitting into evidence employee procedure manuals or certain checks with their memo lines unredacted without a limiting instruction; (2) the court did not err by declining to instruct the jury on the definition of the word “conduct,” by declining to instruct the jury on methods for calculating income taxes, and by failing to provide the jury with relevant statutes; and (3) the court did not err in concluding that Defendant's conduct satisfied the territorial applicability requirement of Maine law. View "State v. Lindell" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for two counts of unlawful sexual contact, holding that sufficient evidence supported the conviction and that there was no error or abuse of discretion in the proceedings below.After a jury trial, Defendant was found guilty of two counts of unlawful sexual contact (Class B). Defendant was sentenced to ten years' imprisonment on the first count and a consecutive term of ten years, suspended, with five years of probation on the second count. The Supreme Judicial Court affirmed, holding (1) there was sufficient evidence to support the convictions; (2) the prosecutor's use of leading questions during the direct examination of the child victim did not violate Defendant's right to a fair trial; (3) testimony by the victim's mother did not violate the first complaint rule; and (4) the sentences imposed were not excessive or disproportionate, and the trial court did not abuse its discretion in imposing consecutive sentences. View "State v. Hansen" on Justia Law

The Supreme Judicial Court dismissed as moot Appellant's appeal from a judgment entered by the superior court ordering the involuntary medical treatment of Appellant, holding that because Appellant was no longer subject to the court's involuntary treatment order, this appeal was moot.Appellant was arrested and charged with burglary and theft by unauthorized taking. While Appellant was in preconviction detention at the mental health unit of the Maine State Prison (MSP) the Department of Corrections filed an application pursuant to Me. Rev. Stat. 34-A, 3049 seeking the involuntary medication of Appellant. The court entered an ex parte order granting the emergency application and permitting the immediate medication of Appellant for a period of 120 days. Appellant appealed. The Supreme Judicial Court dismissed the appeal as moot, holding that because Appellant was no longer at the mental health unit of the MSP and the involuntary treatment order had expired, the appeal was moot and no exceptions to the mootness doctrine applied. View "In re Involuntary Treatment of K." on Justia Law

The Supreme Judicial court vacated the judgment of the trial court denying Defendant's petition for post-conviction review, holding that Defendant must receive a new hearing on his petition.Defendant pleaded guilty of trafficking in prison contraband. Defendant later filed a petition for post-conviction review alleging ineffective assistance by his plea counsel. The court held a hearing and announced that it would grant Defendant's petition. The court began to issue that decision from the bench, but an interruption led the court to resume the hearing. The court then proceeded to deny the petition. The Supreme Court reversed, holding that, under the circumstances of this case, the process at Defendant's hearing irredeemably tarnished the appearance of fairness in the proceeding. View "Evans v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for unlawful sexual contact and domestic violence assault, holding that the prosecutor did not commit misconduct and that the trial court did not abuse its discretion in denying Defendant the opportunity to call as a witness the district attorney's victim witness advocate (VWA).On appeal, Defendant argued that the prosecutor committed multiple instances of misconduct and that the trial court abused its discretion in denying him the opportunity to call the VWA to testify. The Supreme Judicial Court affirmed, holding (1) even if a statement made by the prosecutor was improper, it did not amount to harmful error; (2) the trial court did not abuse its discretion when it denied Defendant's motion for a new trial; and (3) the trial court did not abuse its discretion in denying Defendant's request that the VWA testify. View "State v. Sholes" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part Defendant's judgment of conviction of gross sexual assault, unlawful sexual contact, sexual abuse of a minor, and unlawful sexual touching, holding that there was insufficient evidence to support the convictions of gross sexual assault and unlawful sexual contact.The Supreme Judicial Court remanded the case for resentencing, holding (1) there was sufficient evidence to support Defendant's convictions for sexual abuse of a minor and unlawful sexual touching; and (2) because the State did not present any evidence that Defendant, a substitute teacher, possessed the requisite authority over the victim, a student, at the time that he committed the sexual act and sexual contact, there was insufficient evidence to convict Defendant of gross sexual assault and unlawful sexual contact. View "State v. Conroy" on Justia Law