Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s sentences totaling sixty years following Defendant’s guilty plea to four counts of gross sexual assault. This was Defendant’s second appeal arising out of the events that led to these charges. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court was not required to find specific aggravating circumstances before imposing what Defendant claimed was a de facto life sentence; and (2) the trial court did not impose an illegal sentence because Defendant's aggregate sentence was neither disproportionate to the offenses charged, nor did the sentence offend prevailing notions of decency. View "State v. Hoover" on Justia Law

In 1970, Beauchene was acquitted of a murder charge by reason of mental disease or defect and was committed to the custody of the Department of Health and Human Services, where he remains committed pursuant to 15 M.R.S. 103. In 2016, Beauchene filed a petition seeking a discharge or a modified treatment plan. The court held a hearing at which three mental health professionals testified. The court denied the petition, finding that Beauchene had been diagnosed with “explosive personality,” had escaped from custody in 1973 and was returned to custody in 1978, had escaped again and fled to New York, where he was convicted of rape, sodomy, and assault in 1980, and has mental health symptoms consistent with anti-social personality disorder. The court concluded that Beauchene’s mental condition has “changed very little, if any[,] since” 1970, and if discharged, released, or placed in a modified treatment plan, Beauchene would pose a risk of harm or danger to himself or to others. The Maine Supreme Judicial Court affirmed, finding that Beauchene’s mental health symptoms constituted a “mental disease or defect” and that the statute provides sufficient notice and is not unconstitutionally vague and rejecting a due process claim. View "Beauchene v. State of Maine" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions, entered after a jury trial, for one count of theft by unauthorized taking or transfer, eleven counts of failure to pay tax or file a Maine State tax return, and one count of tampering with public records or information. On appeal, Defendant argued that there was insufficient evidence for the jury to find her guilty of theft and tampering with public records. The Supreme Judicial Court held (1) there was sufficient evidence for the jury to find each element of theft by unauthorized taking beyond a reasonable doubt; and (2) there was sufficient evidence to convict Defendant of tampering with public records. View "State v. Viles" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder, burglary of a dwelling, and theft. The judgment of conviction was entered after a trial in which the State presented the murder charge on alternative theories - intentional or knowing murder and depraved indifference murder. The Supreme Judicial Court held (1) there was sufficient evidence for the jury to find that Defendant was the person who caused the victim’s death; and (2) depraved indifference murder was properly submitted to the jury as an alternative to intentional or knowing murder, and the evidence was sufficient to support any of the alternative theories of murder. View "State v. Cummings" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Mark Gessner’s petition for release from the Riverview Psychiatric Center. On appeal, Gessner argued that the statute governing his opportunity for release from institutional inpatient residency, Me. Rev. Stat. 15, 104-A, was unconstitutionally vague as applied to him. Because Gessner did not raise the vagueness issue to the trial court, the Supreme Judicial Court reviewed for obvious error. The court held (1) considering Gessner’s history of mental illness and violence and his refusal to acknowledge his mental illness or to participate in treatment, the statute’s terms were not unconstitutionally vague for purposes of addressing the individual circumstances at issue in this case; and (2) therefore, Gessner failed to meet his burden of demonstrating that the court committed obvious error. View "Gessner v. State" on Justia Law

Defendant appealed his conviction of unlawful sexual contact, his sentence, and the trial court’s instruction that Defendant register as a Tier III registrant pursuant to the Sex Offender Registration and Notification Act of 2013 (SORNA 2013). The Supreme Judicial Court affirmed the judgment and sentence but clarified that Defendant will be required to register pursuant to SORNA 1999 upon his release from incarceration, holding (1) the motion court did not err in denying Defendant’s motion to suppress his statements to a detective; (2) the court did not abuse its discretion by considering three instances of Defendant’s sexual contact with the victim when it set his basic sentence; and (3) Defendant should have been notified of his duty to register pursuant to SORNA 1999 - not SORNA 2013. View "State v. Seamon" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction finding Defendant guilty of one count each of gross sexual assault, unlawful sexual contact, and sexual abuse of a minor following a jury trial. The court held (1) the trial court’s jury instructions as to the counts for gross sexual assault and unlawful sexual contact correctly informed the jury of the relevant law and the State’s burden of proof; (2) the temporal parameters for the conviction as established by the indictment were sufficient to avoid double jeopardy concerns; and (3) there was competent evidence in the record to support the jury’s guilt verdicts and thus the court’s entry of a judgment of conviction. View "State v. Hodgdon" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer. On appeal, Defendant challenged the constitutionality of Me. Rev. Stat. 17-A, 361-A(2), which creates a permissible inference that a defendant engaged in the conduct that constitutes the crime of theft under certain circumstances. The Supreme Judicial Court affirmed, holding (1) section 361-A(2) is sufficiently clear to give an ordinary person adequate notice of the type of conduct that gives rise to the permissible inference of the specified elements of theft; and (2) Defendant’s contention that section 361-A(2) is subject to, and fails to survive, strict scrutiny was not persuasive. View "State v. Flores-Montecinos" on Justia Law

Appellant appealed from a judgment of conviction after a jury found him guilty of operating under the influence and criminal mischief, arguing that the trial court abused its discretion by admitting an Intoxilyzer test result because the State failed to comply with technical requirements for the admission of the Intoxilyzer test result. The Supreme Judicial Court affirmed, holding (1) the State proved the requirements of paragraphs H and I of Me. Rev. Stat. Ann. tit. 29-A, 2431(2), and therefore, the court did not abue its discretion or clearly err in admitting the test result; and (2) Appellant’s right to due process was not violated by the State’s late disclosure regarding a State’s witness. View "State v. Williamson" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder following a jury trial. Defendant argued that the trial court erred in admitting text messages found in the victim’s cell phone, erred in admitting three photographs of the crime scene in which the victim’s body was visible, and erred by giving the jury what he alleged was a confusing and legally flawed self-defense instruction. The Supreme Judicial Court held that the trial court (1) did not err in admitting the texts because they were relevant, and the State satisfied Me. R. Crim. P. 901’s threshold requirement; (2) informed the jury correctly and fairly in all necessary respects of the governing law, and the instructions were legally accurate; and (3) did not obviously err in admitting the three photographs depicting relevant evidence in this case. View "State v. Marquis" on Justia Law