Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated assault, assault, and attempted kidnapping with the intent to hold for ransom or reward, holding that the court did not err in its instructions to the jury and that there was sufficient evidence to support the convictions.Specifically, the Court held (1) there was sufficient evidence for the jury to have found beyond a reasonable doubt that Defendant was guilty of the convictions; and (2) the court did not err in denying Defendant's requested instructions regarding the meaning of physical health and the use of a dangerous weapon. The Court remanded the case only for dismissal of a fourth count on which the parties intended a dismissal after the court declared a mistrial. View "State v. Hall" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of murder but finding him guilty of felony murder and robbery in connection with a drug-related homicide, holding that Defendant's conviction for both felony murder and the underlying felony of robbery violated the constitutional protection from double jeopardy.Specifically, the Court held (1) the trial court did not err, while exercising its gatekeeping function, by declining to admit certain hearsay statements because the admission of those statements would have run contrary to the truth-seeking function of Me. R. Evid. 804(b)(3); and (2) although Defendant did not raise the double jeopardy issue in the trial court, the State acknowledged that Defendant's convictions for both robbery and felony murder violated the double jeopardy clauses of the state and federal constitutions, and therefore, the case must be remanded for further post-trial proceedings to eliminate the double jeopardy effect arising from the two charges. View "State v. Armstrong" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for murder, holding that that trial court erred by excluding evidence of Defendant's guilty plea to the murder charge but that the error was harmless.Specifically, the Supreme Judicial Court held (1) the court erred by excluding certain evidence purporting to show that Defendant's friend was responsible for the murder, including evidence that Defendant's friend had pleaded guilty to murdering the same victim, but the error was harmless because of the magnitude and strength of the State's evidence; and (2) the sentence of sixty-five years in prison was constitutional and did not violate either the Eighth Amendment to the United States Constitution or Me. Const. art. I, 9, and the sentence was proportionate, even for someone who, like Defendant, was eighteen years old when he was arrested. View "State v. Dobbins" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of eluding an officer, driving to endanger, criminal speeding, and operating after suspension, holding that the trial court did not abuse its discretion.On appeal, Defendant argued that trial court erred by interfering with the State's decision in deciding whether to dismiss the case, in violation of the doctrine of the separation of powers, and by admitting into evidence a photograph taken at the time of his arrest. The Supreme Judicial Court disagreed, holding (1) the court made it clear that the prosecutor was the decision-maker as to whether to dismiss the case; and (2) the court acted within the bounds of its discretion by admitting the photograph. View "State v. Pelletier" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court entering a protection from harassment order against Defendant on the complaint of Jane Doe, holding that the court did not err in issuing the protection from harassment order.Specifically, the Court held (1) the district court did not abuse its discretion in consolidating the hearing on Defendant's motion to dissolve the temporary protection from harassment order and the final hearing on Doe's complaint; (2) the district court did not abuse its discretion in issuing a scheduling order that limited the time for the consolidated hearing to two hours; and (3) the district court did not err in finding credible the testimony of two witnesses and in finding that Defendant intentionally sought to harass Doe. View "Doe v. Plourde" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for manslaughter entered after a jury trial, holding that any error in admitting certain testimony and in challenged remarks made by the prosecutor during closing argument did not require reversal of the conviction.Specifically, the Court held (1) Defendant failed to preserve for review her objection to the admission of certain testimony, and a challenged statement by another witness was not unfairly prejudicial; (2) certain misstatements made by the State during its closing argument did not rise to the level of prosecutorial misconduct; (3) the evidence was sufficient to support the conviction; (4) the trial court did not abuse its discretion in denying Defendant's motion for voir dire and a new trial based on allegations of juror misconduct; and (5) Defendant's sentence is constitutional. View "State v. Scott" on Justia Law

The Supreme Judicial Court affirmed the judgment of divorce entered by the district court after a contested hearing and the court's denial of Father's post-judgment motions to alter or amend the judgment or for a new trial, holding that there was no error in the court's factual findings or any abuse of discretion in its awarding primary residence of the parties' minor child to Mother and establishing a gradually increasing contact schedule for Father.On appeal, Father argued that because the trial judge recused himself sua sponte after the judgment was entered, there may have been undue prejudice by the judge due to the judge's participation in other proceedings involving Father. The Supreme Court affirmed, holding that the record provided no support for Father's claim that the trial judge erred in failing to recuse himself sua sponte during the trial. The Court remanded the matter for further proceedings on Mother's request for attorney fees. View "Schafer v. Schafer" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of theft by unauthorized taking of a firearm and other offenses, holding that the evidence was sufficient to support the convictions and that the court did not err in admitting certain testimony pursuant to the excited utterance exception to the hearsay rule.Specifically, the Court held (1) the evidence was sufficient to support Defendant's conviction of unlawful possession of scheduled drugs; (2) the evidence was sufficient to support Defendant's convictions for theft of a firearm and domestic violence criminal threatening; and (3) the trial court did not err by admitting a witness's testimony regarding statements Defendant's girlfriend made to him after Defendant left the house upon concluding that those statements qualified as excited utterances. View "State v. Curtis" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court dismissing Defendant's petition for post-conviction review as untimely filed, holding that, contrary to Defendant's contention on appeal, the court was not precluded from summarily dismissing the petition based on the statutory filing deadline.Defendant pleaded guilty to aggravated trafficking in scheduled drugs and illegal importation of scheduled drugs. Defendant filed a petition for postconviction review seeking to collaterally attack his conviction on the basis of ineffective assistance of counsel. The trial counsel dismissed the petition as untimely filed. On appeal, Defendant argued that the court erred in determining that there is no duty imposed on trial counsel or the sentencing court to inform Defendant about the deadlines for filing a post-conviction review petition. The Supreme Judicial Court disagreed, holding (1) this Court declines Defendant's invitation to impose a new obligation on sentencing courts to inform defendants about the filing deadline set out in Me. Rev. Stat. 15, 2128-B; (2) trial counsel's failure to inform Defendant of the filing deadline for post-conviction review petitions did not constitute ineffective assistance of counsel or preclude enforcement of the filing deadline. View "Roque v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for burglary, stealing drugs, and violation of a condition of release, holding that the trial court did not err when it denied Defendant's motion to suppress al evidence obtained as a result of the State's acquisition of Defendant's cell phone's location information (CSLI).Specifically, the Supreme Court held (1) because Defendant lacked standing to challenge evidence obtained as a result of the acquisition of a coperpetrator's CLSI, which was the same evidence Defendant sought to exclude based on the acquisition of his own CSLI, this Court need not decide whether the acquisition of Defendant's CSLI was a search under the Fourth Amendment; (2) whether the State violated Defendant's rights under Maine's Electronic Device Location information Act, 16 Me. Rev. Stat. 647 to 650-B, was irrelevant to whether the court erred in denying Defendant's motion to suppress; and (3) the entry into and search of Defendant's residence were lawful. View "State v. O'Donnell" on Justia Law