Justia Criminal Law Opinion Summaries

Defendant was charged by complaint with operating under the influence based in part on an allegation of a blood test measuring 0.15 grams of alcohol per 100 milliliters of blood. Defendant moved to suppress the evidence obtained through the blood test. The trial court granted the motion to suppress, finding that the police officer did not obtain a warrant or seek Defendant’s consent, that Defendant did not consent to the blood test, and that there were no exigent circumstances generating an exception to the warrant requirement. The State appealed. The Supreme Judicial Court affirmed, holding that the record did not compel a finding that Defendant objectively manifested consent to the drawing and testing of his blood through his mere acquiescence and cooperation. View "State v. Boyd" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and theft by deception. Defendant appealed, arguing (1) the evidence presented at trial was insufficient to support the convictions, and (2) the trial court violated her right to be free from double jeopardy by convicting and sentencing her on both counts of theft without consolidating them. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support both convictions; and (2) the trial court did not err by entering a judgment of conviction on each count of theft or by sentencing Defendant on both counts of theft, and furthermore, there was no violation of Defendant’s right to be free from double jeopardy because the convictions and sentences were not based on a single criminal act. View "State v. Hayward" on Justia Law

Defendant pleaded unconditionally guilty to a charge of receiving stolen property. The trial court accepted the open plea, which Defendant never moved to withdraw. Defendant appealed. The State moved to dismiss the appeal on the ground that Defendant cannot take a direct appeal from his plea of guilty absent a challenge to the trial court’s jurisdiction or the constitutionality of his punishment. The Supreme Court granted the motion and dismissed the appeal because Defendant pleaded guilty unconditionally, did not move to withdraw his plea, and did not contend that the trial court lacked jurisdiction or that it imposed an unconstitutional sentence. View "State v. Stevens" on Justia Law

Defendant pleaded guilty to three counts of gross sexual assault and two counts of unlawful sexual contact. The court sentenced Defendant to twenty years’ imprisonment followed by fifteen years of supervised release. Defendant challenged his sentence on appeal, arguing, inter alia, that the supervised release sentencing process, mandated by law, violates the due process clause and the double jeopardy clause. The Supreme Judicial Court affirmed, holding (1) Defendant’s due process argument actually addresses the length of his total sentence, and the sentence is not constitutionally disproportionate or cruel or unusual punishment; (2) the supervised release sentencing process does not violate the Double Jeopardy Clause; and (3) the supervised release statutory scheme does not abrogate the traditional Hewey analysis. View "State v. Parker" on Justia Law

Defendant pleaded guilty of burglary and theft by unauthorized taking or transfer. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements made during a police interview while he was detained in county jail awaiting a court appearance for a probation violation on an unrelated charge because he was not provided with Miranda warnings prior to a custodial interview. The Supreme Judicial Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress because Defendant was not in custody within the meaning of Miranda when he was interviewed by detectives. View "State v. Ames" on Justia Law

After a jury trial, Defendant was convicted of one count of arson. The conviction stemmed from a fire that largely destroyed a diner run by Defendant. Defendant appealed, arguing, inter alia, that the trial court erred by admitting expert testimony concerning the cause of the fire. The Supreme Judicial Court affirmed, holding (1) the trial court did not clearly err by admitting the expert opinion testimony concerning the cause of the fire; (2) the trial court did not abuse its discretion by allowing Defendant’s acquaintance to testify about statements he made to Defendant about how to start house fires; and (3) the evidence was sufficient to establish that Defendant intentionally set the fire. View "State v. Maine" on Justia Law

Defendant entered conditional guilty pleas to three drug-related crimes. Defendant appealed, arguing (1) the information contained in the warrant application to search his home was insufficient to allow a probable cause determination; (2) the court erred in allowing only the State to present evidence at a preliminary hearing that the court considered when denying Defendant’s motion for a Franks hearing; and (3) he made a substantial preliminary showing that entitled him to a Franks hearing. The Supreme Court vacated the judgment, holding (1) the trial court correctly denied that part of Defendant’s motion to suppress challenging probable cause; but (2) the hearing conducted by the trial court must be treated as the beginning of a Franks hearing, and therefore, the court erred by holding a hearing that did not allow Defendant to attempt to meet the burden of production necessary for a full Franks hearing. Remanded for the court to hold a full Franks hearing. View "State v. Thompson" on Justia Law

Defendant pleaded guilty to one count of robbery. Defendant later admitted to four violations of his probation. The court enrolled Defendant in drug court. After he entered the program, Defendant again violated the conditions of his probation. Following a hearing to determine whether to expel Defendant from the drug court program, the court revoked Defendant’s probation and imposed a sentence of five years. Defendant filed a petition for post-conviction review, arguing that his due process and equal protection rights had been violated at the drug court termination hearing. The State moved to dismiss Defendant’s petition based on a lack of subject matter jurisdiction, arguing that Me. Rev. Stat. 15, 2121, 2124 expressly barred post-conviction review of a probation revocation. The court denied the State’s motion to dismiss and granted Defendant’s petition for post-conviction review. The Supreme Court vacated the judgment and remanded with instructions to dismiss the petition for post-conviction review, holding (1) in this case, the proper path to obtain review is to file a notice of appeal; and (2) the court did not abuse its discretion in expelling Defendant from drug court and revoking his probation. View "Spinney v. State" on Justia Law

After a jury trial, Defendant was convicted of baiting deer and hunting from an observation stand overlooking deer bait. The Supreme Court affirmed, holding (1) the instructions given by the trial court fairly and accurately informed the jury of all necessary elements of the governing law, and therefore, Defendant was not deprived of a fair trial; and (2) statements by the prosecutor during his opening and closing that purported to explain that hunting regulations and statutes were premised on a need to keep a level playing field among hunters were improper, but the error was not plain, nor did the error affect Defendant’s substantial rights or the outcome of the trial. View "State v. Lajoie" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence with one prior conviction. Defendant appealed, arguing that the trial court abused its discretion by excluding testimony that certain chemicals could have resulted in a falsely elevated breath-alcohol test if they were present in Defendant’s system when he took the breath test. The Supreme Court affirmed, holding that, under the particular factual circumstances of this case, the trial court did not abuse its discretion by excluding the testimony about the effect of those chemicals on breath-testing equipment and test results produced by that equipment because there was not a sufficient factual foundation to link the testimony with the facts of this case. View "State v. Rourke" on Justia Law