Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of manslaughter after a conditional guilty plea, holding that the State provided sufficient evidence, independent of Defendant's multiple confessions, to establish corpus delicti for the alleged homicide of Defendant's infant son.On appeal, the Court held (1) the trial court made several factual findings, supported by competent evidence in the record, that were sufficient to establish a substantial belief that the infant's death was a result of criminal agency; and (2) there was no reason to depart from the well-established corpus delicti doctrine and to adopt the federal "trustworthiness" standard. View "State v. Hagar" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions but remanded the case for resentencing, holding that the prosecutor did not engage in misconduct during opening statements but that the trial court erred by imposing a sentence within the enhanced range provided by the version of Me. Rev. Stat. Ann. 17-A, 1252(2)(A) that became effective on September 29, 1995.After a jury trial, Defendant was convicted of three counts of gross sexual assault of a person under the age of fourteen and two counts of unlawful sexual contact. The trial court sentenced Defendant to twenty-four years' imprisonment, all but sixteen years suspended, with probation for six years. Defendant appealed. The Supreme Judicial Court affirmed, holding (1) Defendant failed to demonstrate obvious error in the prosecutor's act of alluding to Defendant's supposed confession in his opening statement without ever presenting testimony to support that contention; and (2) Defendant's right to a jury trial was violated when the trial court enhanced the penalty for Defendant's crime beyond what was statutorily authorized after finding an additional fact not pleaded and proved to the jury. View "State v. Pelletier" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence (OUI), holding that the court did not err in concluding beyond a reasonable doubt that Defendant had operated a motor vehicle while intoxicated, in violation of Me. Rev. Stat. 29-A, 2411(1-A)(A).On appeal, Defendant argued that there was insufficient evidence for the court to have found, beyond a reasonable doubt, that Defendant operated a motor vehicle while under the influence. The Supreme Judicial Court disagreed, holding that the court's findings were supported by competent evidence in the record that was sufficient to allow a fact-finder to rationally conclude beyond a reasonable doubt that Defendant operated a motor vehicle while under the influence. View "State v. Bittues" on Justia Law

The Supreme Judicial Court affirmed the sentences entered by the trial court in connection with Defendant's plea of guilty to two murders and a dozen other crimes, holding that the court did not err in imposing two life sentences.The Supreme Court imposed a life sentence for each of the two murders and concurrent sentences of various terms of years for the other crimes. On appeal, Defendant argued that court erred in sentencing him because, in setting the base sentences, the court improperly considered the other crimes that Defendant committed at the time of the murders. Further, Defendant argued that the court improperly double-counted his criminal history. The Supreme Judicial Court affirmed, holding (1) the court engaged in the proper considerations during the sentencing analysis; and (2) the court's recognition of Defendant's violent and dangerous conduct at the time of the murders was neither a misapplication of legal principles nor an abuse of discretion. View "State v. Lord" on Justia Law

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