Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Appellant’s conviction of gross sexual assault, unlawful sexual contact, and furnishing liquor to a minor, holding that the court did not err in determining that Appellant was competent to stand trial.Appellant entered conditional guilty pleas to all three charges. On appeal, Appellant argued primarily that the court erred when it determined that he was competent to stand trial. The Supreme Judicial Court affirmed, holding (1) the party seeking the determination of incompetence must prove by a preponderance of the evidence that the defendant is incompetent to proceed; and (2) the trial court in this case correctly allocated the burden of proof, applied the appropriate evidentiary standard, and did not err in finding Appellant competent to stand trial. View "State v. Gerrier" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of operating under the influence (OUI) with one prior OUI offense, holding that the court did not abuse its discretion during the proceedings below.On appeal, Defendant argued that the court abused its discretion when it ordered that the State would be permitted to use a challenged video recording to impeach Defendant if he testified and contradicted what the video showed, despite the court’s order sanctioning the State by excluding the recording from the State’s case-in-chief. The Supreme Court disagreed, holding (1) the State’s failure to provide Defendant with the recording it intended to offer in evidence within seven days after his plea of not guilty constituted a violation of M.R.U. Crim. P. 16(a)(2)(C); but (2) the court acted within its discretion in declining to exclude the video altogether, and the sanction did not deprive Defendant of a fair trial. View "State v. Matatall" on Justia Law

At issue was whether evidence of the factual circumstances underpinning Defendant’s prior manslaughter conviction was admissible to establish an enhancing factor necessary to convict Defendant of the Class B offense of operating a motor vehicle while under the influence of intoxicants (OUI).Defendant was indicted for aggravated criminal OUI. The indictment alleged that the enhancing factor was Defendant’s 1991 manslaughter conviction that involved the operation of a vehicle while under the influence of intoxicants. The Supreme Judicial Court vacated the order of the unified criminal docket granting Defendant’s motion in limine to exclude evidence of his alleged intoxication at the time he committed his manslaughter offense. The Court held that the trial court erred when it ruled that the State’s proof regarding Defendant’s prior conviction was limited to the face of the prior indictment and judgment and commitment, which did not establish that Defendant was operating while under the influence at the time of the homicide. The Court then vacated the order granting the motion in limine and remanded for entry of an order denying the motion. View "State v. Hastey" on Justia Law

The Supreme Judicial Court affirmed Defendant’s judgment of conviction for operating under the influence (Class D), holding that the motion court did not err by denying Defendant’s motion to suppress evidence of Defendant’s blood-alcohol level obtained following two warrantless blood draws.On appeal, Defendant argued that the motion court erred in finding that exigent circumstances justified two warrantless blood draws and thus denying his motion to suppress evidence of his blood-alcohol level obtained from the second blood draw. The Supreme Judicial Court disagreed, holding that the evidence supported the motion court’s finding that there were exigent circumstances that negated the warrant requirement for both blood draws. View "State v. Martin" on Justia Law

The Supreme Judicial Court affirmed orders of the trial court denying Appellant’s motions to suppress evidence that was seized by the local police department and state police and then returned to the individuals who reported the items stolen, holding that Appellant received a fair trial and that the search warrants were valid.On appeal, Appellant argued that the State failed to preserve exculpatory evidence in violation of his due process right to a fair trial, and that two search warrants failed to designate all of the items to be seized with adequate particularity, making the warrants unconstitutionally vague. The Supreme Judicial Court affirmed, holding (1) even if Appellant made the threshold showing that the evidence at issue was lost or destroyed, he did not demonstrate that any of the evidence had apparent exculpatory value at the time the items were returned to their owners; and (2) the search warrants identified the items to be seized with as much particularity as was possible under the circumstances. View "State v. Winchester" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part an order of the trial court suppressing evidence seized pursuant to a warrantless search of Defendant’s jacket and vehicle, holding that the search of Defendant’s jacket was a lawful search incident to arrest but that the search of Defendant’s vehicle was not supported by probable cause and was outside the scope of a vehicle search incident to arrest.The trial court concluded that the searches of Defendant’s jacket and vehicles and the seizure of the evidence was not supported by probable cause and violated Defendant’s Fourth Amendment rights. The State appealed, arguing that the search of Defendant’s jacket was a lawful search incident to her arrest and that the evidence discovered in the jacket supported the subsequent search for the illegal drugs discovered in Defendant’s vehicle. The Supreme Judicial Court agreed with respect to the search of Defendant’s jacket but vacated the suppression order as to the evidence found in the vehicle. View "State v. Pagnani" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court denying Jerry Philogene’s motion to set aside a default and for relief from a judgment, holding that Philogene demonstrated excusable neglect.The default judgment in this case extinguished Philogene’s property rights to $16,545 in cash seized as part of a civil asset forfeiture proceeding, initiated following a motor vehicle stop and the filing of criminal charges connected with Philogene’s operation of the vehicle. After entry of the default judgment, Philogene filed a motion to set aside the default and for relief from the judgment. The trial court denied the motion, concluding that Philogene’s assumption that his criminal attorney was representing him in the civil forfeiture matter did not constitute excusable neglect and that Philogene’s claim that he possessed the $16,545 in order to purchase a car for his sister did not constitute a meritorious defense. The Supreme Judicial Court disagreed, holding (1) Philogene showed a reasonable excuse for his inattention to the forfeiture proceedings; and (2) Philogene demonstrated a meritorious defense to the underlying charges. View "State v. Philogene" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for four counts of gross sexual assault and other sex offenses, holding that none of Defendant’s assignments of error required reversal.Specifically, the Court held (1) the trial court did not err in denying Defendant’s motion for judgment of acquittal on eight of the eleven counts for which he was convicted because the State is not required to present specific evidence of separate and discrete incidents of abuse for the jury to convict a defendant of every charged offense, as long as the jury is instructed on specific unanimity; (2) Defendant was not unfairly prejudiced by the trial court’s admission into evidence of uncharged sexual abuse; and (3) the trial court did not err in denying Defendant’s motion for judgment of acquittal as to previous unlawful sexual contact charges under the limitations period. View "State v. Reynolds" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of ten charges, including two counts of intentional or knowing murder, holding that the trial court did not err by allowing the jury to consider certain identification testimony.On appeal, Defendant argued that the trial court erred in denying his motion in limine that sought to exclude the identification testimony because the out-of-court identification was produced by an impermissibly suggestive procedure, rendering the testimony unreliable. The Supreme Judicial Court held that the witness’s out-of-court identification was independently reliable, and therefore, the court did not abuse its discretion in admitting the identification testimony. View "State v. Davis" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for aggravated trafficking of scheduled drugs following his guilty plea, holding that the motion court did not err in denying Defendant’s motion to suppress evidence seized by, and statements made to, police officers after he was arrested without a warrant.On appeal, Defendant argued that the police lacked sufficient probable cause to believe that he was engaged in criminal conduct to justify his warrantless arrest. Therefore, Defendant argued, the statements made and evidence seized after the arrest were subject to suppression. The Supreme Judicial Court disagreed, holding (1) sufficient corroborated information warranted any prudent and cautious person to believe that Defendant was committing the offense of heroin trafficking; and (2) therefore, law enforcement officers properly made the warrantless arrest. View "State v. Journet" on Justia Law