Justia Criminal Law Opinion Summaries

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

The Supreme Judicial Court vacated the order of the trial court suppressing evidence obtained during a traffic stop, holding that the motion court erred in restricting its legal analysis to certain evidence.The evidence suppressed in this case was obtained after a Maine State Police trooper stopped and ordered Defendant out of the motor vehicle she was driving so that he could administer field sobriety tests to her. The trial court concluded that the vehicle stop was valid but the subsequently investigatory seizure was not. The Supreme Judicial Court vacated the suppression order, holding that the motion court erred in restricting its analysis to evidence of the events and circumstances occurring at and prior to the moment that the trooper realized that the driver was not the person who was the subject to the complaint that led to the traffic stop. The Court then remanded the case for a determination as to whether the trooper's subsequent actions were reasonably related in scope to the purpose of the initial stop. View "State v. Bennett-Roberson" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court denying in part and granting in part Appellant's petition for post-conviction relief as to his felony convictions, holding that the court erred by denying Appellant's petition despite its determination that Appellant had proved ineffective assistance of counsel for Appellant's misdemeanor charge.Appellant was convicted of both felony and misdemeanor counts. Appellant later filed a petition for post-conviction review, alleging ineffective assistance of counsel. The superior court found that Appellant had been denied his right to effective assistance of counsel by counsel's refusal to discuss Appellant's right to testify but concluded that trial counsel's actions prejudiced Appellant only with regard to Appellant's conviction for misdemeanor theft by unauthorized taking. The Supreme Judicial Court vacated the court's judgment and remanded the case, holding that, as a result of counsel's deficient performance, Appellant was prejudiced in his attempt to defend all charges brought against him, entitling him to post-conviction relief from his convictions on all counts. View "Ford v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs, holding that the court did not err during the proceedings below.On appeal, Defendant challenged the trial court's use of the term "aggravated" in informing the jury of each charge at the beginning of trial and challenged the manner of the court's polling of the jurors. The Supreme Judicial Court affirmed, holding (1) the court's use of the term "aggravated" in one sentence in its introductory remarks to the jury did not constitute obvious error affecting Defendant's substantial rights; and (2) the court did not commit obvious error in its timing of the jury polling. View "State v. Robinson" on Justia Law

The Supreme Judicial Court affirmed Defendant's drug-related convictions, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained as the result of a roadside interaction with a police officer and that any potential challenge to the sentence imposed was not cognizable on direct appeal.Defendant was convicted of unlawful possession of scheduled drugs, unlawful possession of scheduled drugs, and refusing to submit to arrest or detention. On appeal, Defendant argued that his roadside encounter with the officer rose to the level of a detention and was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding (1) the trial court correctly found that the officer's conduct and interaction with Defendant did not rise to the level of a Fourth Amendment seizure; and (2) Defendant's challenge to his sentence was not cognizable on this direct appeal. View "State v. Cunneen" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of domestic violence assault, holding that the trial court did not err in admitting into evidence a recording of a 911 call by the alleged victim of the domestic violence assault for emergency assistance even where the victim did not testify at trial.The trial court concluded that the victim's recorded statements fell within the excited utterance exception to the hearsay rule and that the statements were nontestimonial. The Supreme Judicial Court affirmed, holding that the trial court did not err in determining that the victim's statements on the recording were both excited utterances and nontestimonial and thus not subject to exclusion by the Confrontation Clause. View "State v. Sykes" on Justia Law

The Supreme Judicial Court vacated the aggravating factors that elevated Defendants’ crime from Class B trafficking in schedule drugs to Class A aggravated trafficking in schedule W drugs, holding that there was insufficient evidence to convict Defendant of all four counts.The State charged Defendant with four counts of Class A aggravated trafficking in schedule W drugs. The jury returned a guilty verdict on all four counts. On appeal, Defendant challenged the sufficiency of the evidence supporting his conviction. The Supreme Judicial Court vacated the aggravating elements of Defendant’s convictions and remanded for resentencing on four counts of trafficking in schedule W drugs, holding (1) Me. Rev. Stat. 17-A, 1105-A(1)(E) requires proof beyond a reasonable doubt that the locus of the drug trafficker at the time of the offense be within 1,000 feet of the real property of a school, measured in a straight line and accounting for any difference in elevation between the two points; and (2) there was insufficient evidence that Defendant trafficked within 1,000 feet of a school. View "State v. Brown" on Justia Law