Justia Criminal Law Opinion Summaries

The case involves Ricky Whitney, who was convicted for sexual exploitation of a minor. Whitney had sent messages to a minor, soliciting her to send explicit photographs. The minor, disturbed by the request, showed the messages to her mother, who then took over the conversation, pretending to be the minor. The mother sent a stock photo of a girl in shorts to Whitney, who then sent additional messages soliciting explicit photographs. The court found that the minor did not see these additional messages.The trial court in Penobscot County, Maine, found Whitney guilty of sexual exploitation of a minor and sentenced him to five years in prison. The court also revoked Whitney's probation in a separate matter and imposed the remaining five years of his suspended sentence, to run concurrently with the sentence for the conviction of sexual exploitation of a minor. Whitney appealed, arguing that the evidence was insufficient to support the conviction because the court did not find beyond a reasonable doubt that the minor received the solicitation to send explicit photographs.The Maine Supreme Judicial Court agreed with Whitney. The court found that the statute under which Whitney was convicted requires proof that the person being solicited is actually under the age of sixteen. The court stated that it is not sufficient that a defendant intended to solicit a minor; he must solicit a person who is in fact a minor. Because the trial court explicitly stated that it could not find beyond a reasonable doubt that the minor received the solicitation, an element of the offense was missing. Therefore, the court found there was insufficient evidence to find beyond a reasonable doubt that Whitney committed the crime of sexual exploitation of a minor. The court vacated the judgment of conviction and remanded the case for entry of a judgment of acquittal. View "State v. Whitney" on Justia Law

Corydon Judkins was convicted of domestic violence assault after a jury trial. The case revolved around an incident where the police were called to Judkins' apartment, and the victim alleged that Judkins had assaulted her. The victim's statements were recorded by the responding officer's body camera. However, the victim did not testify at the trial. The State introduced the body camera footage, including the victim's statements, as evidence. Judkins objected, arguing that his constitutional right to confront witnesses was violated as he could not cross-examine the victim. The trial court admitted the footage, citing the excited utterance exception to the hearsay rule.The Maine Supreme Judicial Court reviewed the case. The State conceded that the victim's statements were testimonial and should not have been admitted. The court agreed, stating that once Judkins was removed from the apartment, there was no ongoing emergency that would support the admission of the victim's answers as non-testimonial statements. The court found that the victim's testimonial statements were inadmissible as she did not testify at trial and Judkins had no prior opportunity to cross-examine her.The court then considered whether the error was harmless. It noted that the State relied heavily on the victim's statements in the video to prove its case, and the evidence of Judkins's guilt was not overwhelming. The court also noted that the jury had asked to review the body camera footage during its deliberations. The court concluded that it could not determine beyond a reasonable doubt that the victim's statements on the body camera recording did not affect the verdict. Therefore, the court vacated the judgment and remanded the case for further proceedings. View "State of Maine v. Judkins" on Justia Law

The defendant, James A. Green, was convicted of operating under the influence (OUI) after being found slumped over in his vehicle at a green traffic light. The arresting officer noticed signs of impairment, conducted field sobriety tests, and arrested Green. Another officer, trained as a Drug Recognition Expert (DRE), evaluated Green and found evidence of drug use. Green was charged and pleaded not guilty.Prior to the trial, Green filed a motion to limit the DRE's testimony, arguing that the DRE should not be qualified as an expert under Maine Rule of Evidence 702. He also claimed that the State violated discovery rules by not providing an additional expert witness report from the DRE. The trial court reserved ruling on the DRE's opinions and stated that it would address the issues during the trial if necessary. During the trial, the DRE testified extensively about his background, credentials, and experience, and gave his opinion as a DRE. Green did not object to the DRE's qualifications or opinions during the trial.The jury found Green guilty, and he appealed, arguing that the State violated discovery rules and that the DRE should have been qualified as an expert witness before offering his opinion. The Maine Supreme Judicial Court disagreed, affirming the conviction. The court found that the State had provided the DRE's report as part of automatic discovery, fulfilling its obligations under the Maine Rules of Unified Criminal Procedure 16. The court also found that the DRE's testimony went beyond lay opinion testimony and was informed by his training and certification as a drug recognition expert. However, since Green did not object to the DRE's qualifications or opinions during the trial, his objection was unpreserved and was reviewed for obvious error. The court found no error that deprived Green of a fair trial or resulted in a serious injustice. View "State v. Green" on Justia Law

The case involves Nicholas P. Lovejoy, who was convicted of intentional or knowing murder. Lovejoy appealed his conviction, arguing that the court erred in denying his motion to suppress evidence obtained from an allegedly unlawful traffic stop and a subsequent warrantless search of his home. He also contended that the court abused its discretion in considering his mental state and post-crime conduct in its sentencing analysis.Prior to Lovejoy's conviction, his case was heard in the trial court where he entered a conditional guilty plea. The court denied his motion to suppress evidence obtained from the traffic stop and the search of his home. Lovejoy was subsequently convicted and sentenced to forty-two years of incarceration.In the Maine Supreme Judicial Court, Lovejoy's appeal was reviewed. The court found that the traffic stop was supported by reasonable, articulable suspicion and that the warrantless search of his home was a reasonable response to what law enforcement knew at the time to be an exigent circumstance. The court also concluded that it did not abuse its discretion in sentencing Lovejoy. Therefore, the court affirmed the lower court's decision. View "State of Maine v. Lovejoy" on Justia Law

The case revolves around Jessica A. Williams, who was convicted for depraved indifference murder of her son, Maddox Williams. Maddox was born to Jessica and his father in 2018, and lived with Jessica after his father's arrest in 2020. From October to December 2020, Maddox occasionally had bruises on his body when he came from Jessica's care. In March 2021, Jessica assumed sole custody of Maddox. During her custody, Maddox had multiple injuries, which Jessica attributed to his clumsiness. In June 2021, Maddox was taken to the hospital where he lost consciousness and was pronounced dead. Jessica did not appear to react strongly to Maddox’s death and left the ER shortly after his death. She was later arrested by the police.The trial court had previously heard the case, where the State sought to introduce evidence of prior bad acts by Jessica. Over Jessica's objection, the court granted the motion. At the close of the evidence, Jessica moved for a judgment of acquittal, which the court denied. The jury subsequently returned a verdict of guilty and Jessica was sentenced to forty-seven years in the Department of Corrections.In the Maine Supreme Judicial Court, Jessica appealed her conviction, arguing that the trial court erred in admitting evidence related to a prior bad act, admitting evidence regarding her lack of communication with police officers, and denying her motion for a judgment of acquittal. She also argued that the cumulative effect of all three issues constituted a violation of her due process rights. The court disagreed with her contentions and affirmed the judgment. View "State v. Williams" on Justia Law

The case involves Jaquille J. Coleman, who was convicted for murder and sentenced to forty-seven years in prison. The key facts of the case revolve around the murder of Natasha Morgan, Coleman's former partner and mother of his child. After their relationship ended, Coleman pursued Morgan, leading to an incident where he shot her in front of her mother. The police found bullets and shell casings at the scene and in the car Coleman had been driving, which were confirmed to have been fired from the same gun. Coleman was later found in Mississippi and extradited to Maine.Prior to the Supreme Judicial Court of Maine, Coleman had been convicted by the trial court after a jury trial. He appealed his conviction and sentence, arguing that the trial court had erred in admitting evidence of the victim’s state of mind, denying his motion for a mistrial based on a prosecutorial comment, and considering his failure to express remorse as an aggravating factor in his sentencing.The Supreme Judicial Court of Maine affirmed the lower court's decision. The court rejected Coleman's arguments, ruling that the evidence of the victim’s state of mind was admissible as it was relevant to show Coleman’s motive. The court also found that the prosecutor's comment did not shift the burden of proof to Coleman, and the court's immediate instruction to the jury clarified the burden of proof. Lastly, the court held that the sentencing court properly considered the substance of Coleman’s allocution in assessing lack of remorse as an aggravating factor. View "State v. Coleman" on Justia Law

The case involves Richard Peters, who was convicted for hunting a deer after having killed one and unlawful possession of wild animals. Peters appealed his conviction, challenging the denial of his motions for a mistrial, the sufficiency of the State’s bill of particulars, and the jury instructions. He also argued that double jeopardy protections barred his conviction on the charge of unlawful possession of wild animals.Previously, the trial court had stayed Peters’s sentence to require him to report to the Androscoggin County Sheriff’s alternative sentencing program. However, after Peters appealed, the court amended the stay to require him to surrender to the Penobscot County Sheriff to serve his sentence, interpreting M.R.U. Crim. P. 38(d) strictly.The Maine Supreme Judicial Court disagreed with Peters's contentions and affirmed the judgment. However, the court agreed with Peters that the trial court retained the authority to order the original stay and remanded the case for the trial court to consider whether to reinstate it. The court clarified that the trial court, having determined that the alternative sentencing program was appropriate, retained the discretion to order a stay to effectuate that determination. View "State of Maine v. Peters" on Justia Law

Michael G. Saucier was convicted by a jury in the trial court (Aroostook County, Nelson, J.) for one count of gross sexual assault (Class A), one count of unlawful sexual contact (Class B), and one count of unlawful sexual contact (Class C). The charges stemmed from incidents that occurred when Saucier was the stepfather of the victim. The key issue was whether there was sufficient evidence to prove the victim's age at the time of the offenses, which was a crucial element for each of the charges.The trial court denied Saucier's motion for a judgment of acquittal on all counts, except for one count of unlawful sexual contact (Class B) due to insufficient evidence to prove that the victim was under twelve years old when the offense occurred. The jury found Saucier guilty on the remaining three counts. Saucier was sentenced to twenty-two years for the Class A offense, with nine years for the Class B offense and five years for the Class C offense, all to be served concurrently.On appeal, the Maine Supreme Judicial Court found that the evidence regarding the victim's age was sufficient to sustain a conviction on the Class C offense but not on the Class A and B offenses. The court noted that the State failed to provide evidence to identify the victim's date of birth or her age during the relevant time period. The court concluded that while the jury could reasonably infer that the victim was under fourteen during her time in Exeter, no such inference could be made that she was under the age of twelve. Consequently, the court vacated the convictions on the Class A and B offenses, affirmed the conviction on the Class C offense, and remanded the case for resentencing on the Class C offense. View "State v. Saucier" on Justia Law

The case involves Roger Ouellette, who was convicted of Operating Under the Influence (OUI) following a police stop in his driveway. The police officer had observed Ouellette's vehicle crossing the center line of the road, which led the officer to suspect a violation of traffic laws. Ouellette entered a conditional guilty plea after his motion to suppress evidence obtained from the stop was denied by the trial court.The trial court found that the officer had reasonable suspicion to stop Ouellette due to his observed traffic violation. Ouellette argued that the stop was unjustified as the officer lacked reasonable suspicion of wrongdoing. However, the court determined that the stop was supported by reasonable articulable suspicion that Ouellette had violated the motor vehicle statute requiring vehicles to be operated within a single lane.On appeal, Ouellette argued that the stop was an unreasonable seizure under the Fourth Amendment because it occurred within the curtilage of his home without a warrant and without any applicable exception to the warrant requirement. The Maine Supreme Judicial Court affirmed the lower court's decision, concluding that the court's failure to grant Ouellette’s motion on that ground did not constitute obvious error and that the stop was justified based on reasonable suspicion. The court also found that Ouellette's argument regarding the stop occurring within the curtilage of his home was unpreserved and did not amount to obvious error. View "State of Maine v. Ouellette" on Justia Law

Randall J. Weddle was involved in a major motor vehicle accident in Washington, Maine, which resulted in the death of two drivers. The accident involved five vehicles, one of which was engulfed in flames. Weddle, the driver of a large tractor trailer, was found to be the cause of the accident. Hospital tests revealed that Weddle had alcohol in his system and officers found a three-quarters-full whiskey bottle and a shot glass in his truck several days after the accident.Weddle was charged with two counts of manslaughter, two counts of aggravated criminal operating under the influence, one count of causing injury while operating under the influence, one count of aggravated driving to endanger, one count of driving to endanger, and eight counts of violating commercial motor carrier operator rules. The jury found Weddle guilty of all counts. The court conducted a sentencing analysis and set the basic sentence at twenty years, considering the nature and circumstances of the crime. The court set the maximum sentence at thirty years, weighing mitigating and aggravating factors. The final sentence was set at thirty years, with all but twenty-five years suspended, followed by four years of probation.Weddle appealed his sentence to the Maine Supreme Judicial Court. He argued that his sentence was unconstitutional because it was not proportioned to the offense and that it was excessively harsh. The court affirmed the sentence, concluding that the sentence was not greatly disproportionate to the offense and did not offend prevailing notions of decency. The court also found that the sentence was not excessively harsh, as the court had considered both aggravating and mitigating factors in setting the maximum sentence. View "State of Maine v. Weddle" on Justia Law