Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court granting Appellant’s petition for postconviction relief and vacating his conviction of sexual abuse of a minor, holding that the court’s factual findings were supported by competent evidence in the record.After a hearing, the postconviction court found that Appellant had been deprived of the effective assistance of counsel and vacated his conviction. The Supreme Court affirmed, holding that the postconviction court’s finding that Appellant had been deprived of the effective assistance of counsel at trial was supported by competent record evidence. View "Fahnley v. State" on Justia Law

The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress his blood-alcohol test results as having been procured without a warrant and without voluntary consent, holding that Defendant consented to the blood test.The blood test was taken upon probable cause to believe that the ability of Defendant, the driver of the motor vehicle, to operate the vehicle was impaired by intoxicants. On appeal, Defendant argued that the blood test was unconstitutional because it was taken without a warrant and her consent to the test was rendered involuntary by the warning of an increased minimum sentence if she refused to consent and was then convicted. The Supreme Judicial Court disagreed, holding that no coercion results from a law enforcement officer’s statement to a driver that, if she is ultimately convicted of operating under the influence, her failure to submit to a blood draw would subject her to an enhanced criminal penalty, including a minimum mandatory jail term. View "State v. Lemeunier-Fitzgerald" on Justia Law

The Supreme Court dismissed the appeal brought by Sharon Carrillo from an order of the trial court denying her motion to disqualify the State’s attorneys from further participation in her prosecution for murder, holding that the appeal was interlocutory.Carrillo moved to disqualify the State’s attorneys for participating further in her prosecution, arguing that the prosecutors committed ethical violations by obtaining certain subpoenaed information. The trial court denied the motion to disqualify, determining that the prosecutors’ error did not warrant the extraordinary remedy of disqualification. Carrido appealed. The Supreme Court dismissed the appeal as interlocutory, holding the Carrillo did not meet her burden of demonstrating that the exception to the final judgment rule applied. View "State v. Carrillo" on Justia Law

The Supreme Court held that a bail condition order prohibiting Defendant from possessing a “dangerous weapon” issued by a New Hampshire bail commissioner was a “similar order issued by a court…of another state” pursuant to Me. Rev. Stat. 19-A 4011(1)(A), and therefore, the State could prosecute Defendant for an alleged violation of that order.Defendant filed a motion to dismiss charges against him for violating a protective order. The trial court granted the motion to dismiss, concluding that any alleged violation in Maine of the New Hampshire conditions order could not subject Defendant to prosecution because the order failed to meet the definition of a “similar order” of protection “issued by a court…of another state” pursuant to section 4011(a)(A). The Supreme vacated the judgment and remanded the case to the trial court, holding that the New Hampshire order was a “similar order” under the statute. View "State v. Blum" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of assault, holding that Defendant was not denied a fair trial because one of the jurors reported that she had felt pressured to return a guilty verdict.After the court informed the parties of the juror’s statement and invited the parties to be heard, the court concluded that there was no evidence of juror misconduct and that the guilty verdict would stand. The Supreme Judicial Court held that Defendant was not deprived of a fair trial because there was no evidence of outside influence, bias, or misconduct, and therefore, the juror’s statement that she felt pressured to return a guilty verdict fell within the categories of evidence prohibited from use by Me. R. Evid. 606(b)(1). View "State v. Leon" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of aggravated assault.Defendant, a mixed martial arts fighter, repeatedly punched the victim in the head, rendering the victim unconscious. A jury found him guilty of aggravated assault. On appeal, Defendant argued that there was insufficient evidence to support his conviction and that there was insufficient evidence supporting a finding that the State disproved self-defense. The Supreme Court disagreed, holding that the State presented sufficient evidence to prove that Defendant manifested an extreme indifference to the value of human life and to disprove Defendant’s self-defense justification beyond a reasonable doubt. View "State v. Matthews" on Justia Law

The Supreme Judicial Court dismissed the appeal brought by Appellant challenging his sentence requiring him to pay $7,500 in restitution based on his involvement in damaging rental property from which he was evicted. The appeal was dismissed because Appellant did not properly assert that there was any illegality apparent on the record. Rather, Appellant challenged only the factual and discretionary determinations of the lower court. Because these are decisions that the Supreme Judicial Court does not review in a direct appeal of a sentence, the Court dismissed Appellant's appeal. View "State v. Plante" on Justia Law

The Supreme Judicial Court dismissed Appellant’s appeal from a judgment of conviction of manslaughter following Appellant’s unconditional open guilty plea, holding that Appellant provided no persuasive reason for the Court to depart from its longstanding jurisprudence strictly limiting direct appeal following a guilty plea.On appeal, Appellant argued that his plea was involuntary because he was coerced to accept the truth of all the facts recited by the State at the plea hearing and that he should not be required to show cause as to why his appeal should not be dismissed pursuant to State v. Huntley, 676 A.2d 501 (Me. 1996), and its progeny, which provide that a defendant may not appeal from a conviction entered upon his guilty plea except under certain circumstances. Because Appellant did not move to withdraw his unconditional plea before the court imposed the sentence and did not assert that the trial court lacked jurisdiction or that it imposed an excessive, cruel, or unusual sentence, this appeal must be dismissed. View "State v. Adams" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the sentencing court following Defendant’s guilty plea to an information charging him with felony murder. The sentencing court imposed a prison sentence of twenty years, all but ten years suspended, with four years’ probation and a restitution order. On appeal, Defendant argued that his sentence was unconstitutionally disproportionate and denied his constitutional right to equal protection. The Supreme Judicial Court disagreed, holding (1) Defendant’s offense and sentence did not generate an “inference of gross disproportionality”; and (2) notwithstanding the fact that Defendant’s codefendant received only a seven-year sentence, Defendant’s sentence did not violate Defendant’s equal protection rights. View "State v. Lopez" on Justia Law

The Supreme Judicial Court affirmed Defendant’s sentence entered in the Unified Criminal Docket following Defendant’s guilty plea to two counts of aggravated criminal operating under the influence and possession of a firearm by a prohibited person.On appeal, Defendant argued that, notwithstanding an agreement with the State that his sentence would not exceed an agreed upon “cap,” the sentencing court was required to explain its selection of the basic, maximum, and final periods of incarceration. In affirming, the Supreme Judicial Court held that any error in the court’s articulation of the sentence was not sufficiently prejudicial to affect the outcome of the proceeding and did not affect Defendant’s substantial rights. View "State v. Bean" on Justia Law