Justia Criminal Law Opinion Summaries

The district court granted Defendant’s motion to suppress evidence that resulted in a criminal complaint charging Defendant with operating under the influence, concluding that a police officer violated the Fourth Amendment when he ordered Defendant to leave his house in order to complete a traffic stop due to defective license plate lights. The district court concluded (1) the officer did not have probable cause to suspect any criminal activity, and no exigent circumstances existed when he ordered Defendant to exit his house; and (2) the officer’s verbal order to come outside amounted to an unlawful seizure of Defendant. The Supreme Judicial Court vacated the order of suppression, holding (1) the police officer had probable cause to arrest Defendant for the crime of failure to stop his vehicle on request or signal of a uniformed law enforcement officer and pursued him immediately and continuously from the scene of the crime into the curtilage of his home; and (2) therefore, the seizure of Defendant did not amount to unlawful seizure or arrest. View "State v. Blier" on Justia Law

The Supreme Judicial Court vacated an order entered by the trial court suppressing evidence seized from Defendant, his vehicle, and his residence after the court concluded that the warrant authorizing the search and seizure of the evidence was not supported by probable cause. On appeal, the State argued that the information presented in the warrant affidavit was sufficient for the warrant judge to find that there was probable cause that evidence of a crime would be found in Defendant’s car, in his home, and on his person. The Supreme Judicial Court agreed, holding that the warrant affidavit provided the necessary substantial basis for the warrant judge’s finding of probable cause. View "State v. Mariner" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for one count of intentional or knowing or depraved indifference murder following a jury trial. On appeal, Defendant argued that the trial court abused its discretion in denying his motion for a new trial on the grounds of prosecutorial misconduct and error in admitting evidence of prior bad acts. The Supreme Judicial Court held (1) the prosecutor’s remarks during opening statements did not deprive Defendant of a fair trial; and (2) the trial court did not clearly err or abuse its discretion in admitting evidence of Defendant’s prior assault of the victim. View "State v. Pillsbury" on Justia Law

The Supreme Judicial Court held that the trial court did not err in refusing to instruct the jury during Defendant’s criminal trial that the jury needed to find that Defendant had acted intentionally or knowingly in order to find him guilty of possessing a loaded firearm in a motor vehicle and unlawfully driving deer. The Court concluded (1) the firearm offense is a strict liability crime and, therefore, no mens rea instruction was necessary; and (2) the crime of driving deer is not a strict liability crime and contains a mens rea component, but because the trial court’s instructions adequately and correctly conveyed the elements of both crimes to the jury, the trial court did not err in refusing Defendant’s jury instruction request. View "State v. Siracusa" on Justia Law

The Supreme Judicial Court held that the trial court did not err in excluding one of Defendant’s statements from a recorded interview with police that was admitted at Defendant’s jury trial, holding that the court’s exclusion of the statement that the victim “likes it rough” was not prejudicial to Defendant’s defense and did not violate his right to due process. In addition, the Court was unpersuaded by Defendant’s contention that the statement was admissible pursuant to Me. R. Crim. P. 412(b). The Court thus affirmed Defendant’s judgment of conviction for gross sexual assault, assault, domestic violence criminal threatening, and criminal restraint. View "State v. Grindle" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for operating under the influence, holding that the trial court did not err in concluding that Defendant’s defense that his operation of a motor vehicle was involuntary did not apply to the facts of this case. Specifically, the Court held (1) the trial court erred in concluding that the involuntariness defense can never apply to strict liability crimes; but (2) the court did not err to the extent that it concluded that the defense of voluntariness did not apply to the facts of the matter before it. During trial, Defendant argued that his conduct was directed by “command hallucinations,” and therefore, the involuntary conduct defense applied in this case. View "State v. Griffin" on Justia Law

Defendant appealed his conviction of operating under the influence (OUI) with a refusal to submit to a chemical test and of operating after suspension (OAS), arguing (1) the State failed to lay a proper foundation for the admission of testimony regarding horizontal gaze nystagmus (HGN) tests performed on Defendant after he was stopped for a traffic violation; and (2) the court committed obvious error by considering testimony from the OUI portion of the trial - as presented to the jury - to conclude that the State proved the operation element of the OAS charge - which was decided by the court. The Supreme Judicial Court affirmed, holding (1) the State laid a proper foundation for the admission of testimony regarding the HGN tests pursuant to State v. Taylor; and (2) where the trial court did not formally sever the OAS and OUI charges and, rather, the parties agreed before trial to have the court decide the OAS charge for “strategic reasons,” the court did not commit obvious error when it considered testimony presented to the jury on the OUI charge in deciding the OAS charge. View "State v. Hinkel" on Justia Law

Defendant was convicted of domestic violence assault, domestic violence stalking, and endangering the welfare of a child. The Supreme Judicial Court vacated the judgment of conviction as to the charge of domestic violence assault and remanded for entry of a judgment of acquittal on that charge, holding that the record contained insufficient evidence for the jury to find, beyond a reasonable doubt, that Defendant’s conduct forming that basis for domestic violence assault occurred within the relevant limitations period. The Court also remanded to determine whether resentencing was necessary as to the stalking and endangering the welfare of a child charges. View "State v. Lacourse" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated assault, two counts of domestic violence assault, and related offenses. Defendant appealed, arguing, inter alia, that the court erred in denying his motion to suppress statements he made to a police officer prior to his arrest. Defendant also appealed his sentence. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that Defendant was not in custody for Miranda purposes and consequently denying his motion to suppress; (2) the court did not abuse its discretion in admitting the testimony of an expert witness who testified about the causes, effects, and symptoms of strangulation; and (3) the court did not abuse its discretion in sentencing Defendant. View "State v. Perry" on Justia Law

After a jury trial, Defendant was found guilty of one count of murder. The Supreme Judicial Court affirmed the judgment, holding (1) the motion court did not err in denying Defendant’s motion to suppress statements he made to law enforcement officers prior to 12:44 p.m. on July 18, 2013 because Defendant was not in custody for Miranda purposes that morning; (2) the motion court did not err in concluding that the Miranda violation occurring after 12:44 p.m. on July 18 did not mandate suppression of statements made on July 23 and 24; (3) the State’s attorney did not commit prosecutorial misconduct during opening statement and closing argument; and (4) the State presented sufficient evidence to support the murder conviction. View "State v. Cote" on Justia Law