Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of aggravated assault and violating a condition of release, holding that the sanctions imposed on the State were sufficient to remedy the prejudice caused by discovery violations and that there were no other errors in the proceedings below.Specifically, the Court held (1) the court did not abuse its discretion to impose sanctions for the State's discovery violations; and (2) Defendant was not deprived of his Sixth Amendment right to an impartial jury that represented a fair cross section of Defendant's community, and accordingly, the trial court did not err in denying Defendant's motion for a new jury. View "State v. Townes" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review asserting that he had received ineffective assistance of counsel at a probation revocation hearing, holding that the trial court did not err but, as recently announced in Petgrave v. State, __ A.3d ___ (2019), Defendant now has a procedure by which he can pursue his claim.In Petgrave, the Supreme Judicial Court held that a defendant has a right to the effective assistance of counsel at a revocation hearing and that a defendant who contends that he or she received ineffective assistance of counsel at a probation revocation hearing may pursue that claim by filing a properly supported motion for a new trial pursuant to M.R.U. Crim. P. 33. In the instant case, the Court held that Appellant may file a motion for a new revocation hearing in the trial court within thirty-five days following the issuance of the Court's mandate. View "Gould v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of aggravated criminal mischief and did not reach the State's claim of error on cross-appeal, holding that the evidence was sufficient for the jury to rationally find and conclude that the State proved each element of the offense of aggravated criminal mischief beyond a reasonable doubt.On appeal, Defendant argued that the State had not proved that he had damaged the "property of another" - a critical element of aggravated criminal mischief. On cross-appeal, the State challenged the denial of its motion to correct the sentence because the court did not order restitution. The Supreme Judicial Court affirmed, holding (1) the jury rationally could have inferred that Defendant intentionally, knowingly, or recklessly caused damage to the property of another; and (2) because the State failed to file an appeal and obtain the written approval of the Attorney General to appeal the court's decision, this Court did not reach the State's claim of error. View "State v. Ouellette" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for failure to sign a criminal summons, refusing to submit to arrest by physical force, and assault, holding that the trial court abused its discretion by excluding from evidence a cellphone video taken by the defendant's sister that showed some of the events that occurred during Defendant's arrest.Specifically, the Court held (1) because the trial court did not rely on Me. R. Evid. 403 when excluding the video at issue and because the video was properly authenticated, the court's refusal to admit the video so that the jury could view it was an abuse of discretion; and (2) the trial court's exclusion of the video was not harmless error. View "State v. Hussein" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review alleging ineffective assistance of counsel in his probation revocation matter but that Appellant may file a motion for a new probation revocation hearing in the trial court within thirty-five days of the issuance of this mandate.The trial court concluded that Appellant's remedy for any claim of error arising from the revocation was to seek a discretionary appeal, as Appellant had already done. The Supreme Judicial Court held (1) in a probation revocation hearing, a defendant has a right to the effective assistance of counsel; (2) Appellant's motion was properly dismissed, but Appellant was deprived of an opportunity to obtain meaningful review on his claim; and (3) a defendant who seeks to raise a claim of ineffective assistance of counsel after a probation revocation hearing may do so by filing a motion under Rule 33 of the Maine Rules of Unified Criminal Procedure for a new trial, which must be filed thirty-five days after the entry of judgment, and the judge who issued the revocation judgment will, if the defendant has made out a prima facie claim of ineffective assistance, will hold an evidentiary hearing or dismiss the motion. View "Petgrave v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of operating under the influence, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained from a blood draw and that the court's jury instructions were sufficient and appropriate.Prior to trial court, Defendant filed a motion to suppress evidence from the blood draw and the corresponding blood-alcohol test result, arguing that the evidence was obtained without valid consent. The trial court denied the motion. After closing arguments, Defendant requested a curative instruction to remedy the State's alleged misstatement of the evidence in its closing argument. The court declined to give such an instruction. The jury subsequently found Defendant guilty of operating under the influence. The Supreme Judicial Court affirmed, holding (1) Defendant had the capacity to give knowing consent to the blood draw, and his consent was voluntary; and (2) the prosecutor's closing statements to the jury did not misstate the evidence, demonstrate bad faith, or create any prejudice. View "State v. Ayotte" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder, holding that the court did not abuse its discretion by admitting Facebook Messenger records into evidence and that there was sufficient evidence to support the jury's verdict.On appeal, Defendant argued that the court erred in admitting Facebook Messenger records because they were not properly authenticated and that they were improperly admitted pursuant to the hearsay exception that allows for the admission of a declarant's statement of his then-existing statement of mind. The Supreme Judicial Court affirmed, holding (1) the court did not err or abuse its discretion when it found the Facebook Messenger records to be authenticated under Me. R. Evid. 901; (2) assuming that the Facebook Messenger statements were hearsay, they were improperly admitted under Me. R. Evid. 803(3), but the error was harmless; and (3) there was sufficient evidence for the jury to find Defendant guilty of murder. View "State v. Tieman" on Justia Law

The Supreme Judicial Court affirmed the order of the trial court imposing a discovery sanction following the State's failure to provide Defendant with a dash-cam video of Defendant allegedly committing the crime for which he was charged, holding that a serious sanction was warranted and that the court's choice of sanction was well within its discretion.Defendant was indicted for operating after revocation. Defendant subsequently sent the State a discovery request letter requesting any video or audio that would have been created as part of the stop that led to Defendant's arrest. Although the State had access to the arresting officer's dash-cam video of the stop, the State failed to turn over the video, arguing that it had no "evidentiary value." The trial court ultimately granted Defendant's request to suppress the evidence as a sanction for the State's discovery violation. The Supreme Judicial Court affirmed, holding that the court did not err in finding a discovery violation or abuse its discretion in selecting a sanction that effectively ended the prosecution. View "State v. Reed-Hansen" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court entering a protection from harassment order against Appellant, holding that the facts as found by the court were sufficient to prove that Appellant's actions constituted criminal mischief, which constitutes an act of harassment.In entering the order of protection from harassment against Appellant for one year the district court found that Appellant had committed three or more acts of harassment pursuant to Me. Rev. Stat. 5, 4651(2)(A). The Supreme Judicial Court affirmed, holding (1) the court erred in finding because there were three or more acts of harassment; but (2) the court's findings were sufficient to establish the elements of criminal mischief, which can stand alone as a single act of harassment. View "Allen v. Rae" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in favor of the State on the State's complaint against Defendants for fraudulent transfer pursuant to Me. Rev. Stat. 14, 3575(1)(A), holding that the State's complaint was timely filed and that the court's findings were supported by competent evidence in the record.On appeal, Defendants argued that the State's action was barred by Me. Rev. Stat. 14, 3580(1). Under that statute, a cause of action with respect to a fraudulent transfer is extinguished unless brought within six years after the transfer or, if later, within one year after the transfer was or reasonably could have been discovered. The superior court determined that Defendants were equitably estopped from asserting the bar set out in section 3580(1) as an affirmative defense. The Supreme Judicial Court held (1) section 3580 is a statute of repose that has displaced the common law doctrine of estoppel on which the court relied in rejecting Defendants' section 3580(1) defense; but (2) the court's factual findings applied to trigger the one-year discovery exception to the six-year limitation provided in the statute. View "State v. Tucci" on Justia Law