Justia Criminal Law Opinion Summaries

The Supreme Judicial Court vacated the order of the trial court quashing Appellant’s subpoenas of mental health records of the alleged victim without first viewing the records in camera and remanded for the production and in camera review of some or all of the requested mental health records.Appellant was convicted of gross sexual assault of a person under the age of fourteen and unlawful sexual contact. On appeal, Appellant challenged the court’s decision to quash his subpoenas of the mental health records, the court’s denial of his motion to suppress statements made to law enforcement, and the court’s denial of his motion for a judgment of acquittal. The Supreme Court held (1) the trial court did not err in its rulings on either Appellant’s motion to suppress or his motion for a judgment of acquittal; but (2) because it was relatively certain that the records contained some evidence concerning the exact crimes charged, and the identity of the alleged perpetrator was directly at issue at trial, due process demanded that the court must proceed with an in camera review. View "State v. Olah" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder. The Court held (1) the trial court did not abuse its discretion or commit obvious error when it excluded evidence that the State of Maine’s Chief Medical Examiner had been removed from his former position as Chief Medical Examiner for the Commonwealth of Massachusetts; and (2) the trial court did not err, much less commit obvious error, when it instructed the jury on how it could evaluate evidence of flight to avoid prosecution. View "State v. Haji-Hassan" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder. The Court held (1) the trial court did not abuse its discretion or commit obvious error when it excluded evidence that the State of Maine’s Chief Medical Examiner had been removed from his former position as Chief Medical Examiner for the Commonwealth of Massachusetts; and (2) the trial court did not err, much less commit obvious error, when it instructed the jury on how it could evaluate evidence of flight to avoid prosecution. View "State v. Haji-Hassan" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for three counts of murder and one count of gross sexual assault and the sentences of life imprisonment imposed on each of the murder counts. The Court held (1) the trial court abused its discretion by foreclosing Defendant’s cross-examination of the State’s Chief Medical Examiner concerning his termination from his position as the Chief Medical Examiner in Massachusetts, but the error was harmless; (2) the trial court did not clearly err by finding that the State had sufficiently established the chain of custody of the sexual assault kit used during the autopsy of one of the victims; (3) there was sufficient evidence to support the jury’s guilty verdict on the gross sexual assault charge; (4) the State did not commit prosecutorial misconduct in its opening statement; and (5) the trial court applied a correct standard of proof and did not abuse its discretion in determining the facts considered at sentencing. View "State v. Coleman" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for three counts of murder and one count of gross sexual assault and the sentences of life imprisonment imposed on each of the murder counts. The Court held (1) the trial court abused its discretion by foreclosing Defendant’s cross-examination of the State’s Chief Medical Examiner concerning his termination from his position as the Chief Medical Examiner in Massachusetts, but the error was harmless; (2) the trial court did not clearly err by finding that the State had sufficiently established the chain of custody of the sexual assault kit used during the autopsy of one of the victims; (3) there was sufficient evidence to support the jury’s guilty verdict on the gross sexual assault charge; (4) the State did not commit prosecutorial misconduct in its opening statement; and (5) the trial court applied a correct standard of proof and did not abuse its discretion in determining the facts considered at sentencing. View "State v. Coleman" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of arson. On appeal, Defendant argued that the trial court violated his right to be protected against double jeopardy by admitting in his trial evidence on which the State relied to try to prove some of the charges of which Defendant was acquitted in a prior trial. The Supreme Judicial Court agreed, holding that the admission of that evidence was barred by collateral estoppel and violated Defendant’s right to be protected from double jeopardy and that the error was not harmless. View "State v. Weckerly" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant of arson. On appeal, Defendant argued that the trial court violated his right to be protected against double jeopardy by admitting in his trial evidence on which the State relied to try to prove some of the charges of which Defendant was acquitted in a prior trial. The Supreme Judicial Court agreed, holding that the admission of that evidence was barred by collateral estoppel and violated Defendant’s right to be protected from double jeopardy and that the error was not harmless. View "State v. Weckerly" on Justia Law

The Supreme Judicial Court affirmed the trial court’s judgment convicting Defendant of three counts of possession of sexually explicit material, thus denying Defendant’s challenges to the denial of his motion to suppress statements and digital evidence obtained by the police after they entered his home. On appeal, Defendant argued that the trial court erred in finding that he consented to the police officers’ entry into his home, which resulted in the search and seizure of his computer. The Supreme Judicial Court held that there was sufficient evidence in the record to support a finding that Defendant consented to the officers’ entry. View "State v. Marquis" on Justia Law

The Supreme Judicial Court affirmed the trial court’s judgment convicting Defendant of three counts of possession of sexually explicit material, thus denying Defendant’s challenges to the denial of his motion to suppress statements and digital evidence obtained by the police after they entered his home. On appeal, Defendant argued that the trial court erred in finding that he consented to the police officers’ entry into his home, which resulted in the search and seizure of his computer. The Supreme Judicial Court held that there was sufficient evidence in the record to support a finding that Defendant consented to the officers’ entry. View "State v. Marquis" on Justia Law

In this criminal case, the Supreme Court dismissed Defendant’s appeal from the dismissal of his motion to vacate as moot and remanded the case for further proceedings.While Defendant’s competency to stand trial was under consideration and his motion to dismiss the charges on the basis of prosecutorial misconduct was pending, the trial court held an ex parte conference with the prosecutor to discuss the alleged prosecutorial misconduct. Defense counsel was not notified of the conference and did not consent to the ex parte communication. The same jurist later found Defendant competent to stand trial, denied Defendant's motion to dismiss, and denied Defendant’s motions to suppress. Defendant then entered a conditional guilty plea. While Defendant’s appeal remained pending, the Supreme Court authorized additional proceedings in the trial court so Defendant could obtain the transcript of the ex parte conference. Defendant then filed a motion to vacate the judgment of conviction and motion for the jurist’s recusal. The jurist recused himself. The court then dismissed Defendant’s motion to vacate. On appeal, the Supreme Court vacated all adjudicatory action undertaken after the ex parte conference and dismissed Defendant’s appeal form the dismissal of the motion to vacate as moot. View "State v. Bard" on Justia Law