Justia Criminal Law Opinion Summaries
Articles Posted in Maine Supreme Judicial Court
State v. Saenz
After a jury-waived trial, Defendant was convicted of depraved indifference murder for the death of his wife, who died after several days of beatings and injuries inflicted on her by Defendant while her children were present. Defendant appealed, challenging the sufficiency of the evidence to support his conviction. The Supreme Court affirmed, holding that there was sufficient evidence for the court to have found beyond a reasonable doubt that (1) Defendant’s actions, including his abuse of his wife over days, along with his delay in seeking medical assistance, caused his wife’s death; and (2) Defendant acted with a depraved indifference to the value of human life in killing his wife. View "State v. Saenz" on Justia Law
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Criminal Law, Maine Supreme Judicial Court
State v. Lagasse
After a jury trial, Defendant was convicted of aggravated trafficking of scheduled drugs. Defendant appealed, arguing that the superior court erred by denying his motion to suppress evidence of drugs that the arresting officer found on and near Defendant when he was arrested. Specifically, Defendant contended that the police lacked probable cause for his warrantless arrest because, inter alia, the stop for Defendant’s failure to use a turn signal was pretextual and the officer lacked reasonable articulable suspicion to stop the vehicle. The Supreme Court affirmed, holding that Defendant’s stop and arrest were lawful, and therefore, the superior court did not err by denying Defendant’s motion to suppress. View "State v. Lagasse" on Justia Law
State v. Carter
After a jury-waived trial, Defendant was convicted of solicitation of a child to commit a prohibited act. The trial court imposed a suspended jail term of six months and one year of probation. Defendant appealed, arguing, among other things, that the trial court erred in failing to apply the affirmative defense of renunciation. The Supreme Judicial Court affirmed, holding (1) the trial court did not err by failing to find Defendant not guilty based on the affirmative defense of renunciation; and (2) the evidence was sufficient to support Defendant’s conviction generally. View "State v. Carter" on Justia Law
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Criminal Law, Maine Supreme Judicial Court
State v. Maderios
After a jury trial, Defendant was found guilty of two counts of aggravated assault and two counts of domestic violence assault. The Supreme Judicial Court affirmed, holding that the trial court did not err in (1) excluding the prospective testimony of three of the victim’s former romantic partners regarding her alleged propensity to make false accusations when relationships ended against her wishes; (2) denying Defendant’s motion to exclude audio recordings and photographs made by the victim on the ground that their admission violated the best evidence rule; and (3) declining to grant a mistrial as a result of statements made by the prosecutor during the State’s closing and rebuttal arguments. View "State v. Maderios" on Justia Law
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Criminal Law, Maine Supreme Judicial Court
State v. Foster
After a jury trial, Defendant was convicted of two counts of gross sexual assault, four counts of impersonating a public servant, and two counts of engaging a prostitute. The convictions were based on Defendant’s pretending to be a police officer in order to induce three of four women who were engaged in prostitution to have sex with him as he demanded. Defendant appealed, arguing that the indictment and jury verdict form did not adequately distinguish among separate allegations involving each victim, in violation of his due process rights. The Supreme Judicial Court affirmed, holding that the constitutional issues that Defendant now asserts were waived. View "State v. Foster" on Justia Law
State v. Hederson
Defendant was arrested in New Hampshire on a domestic violence charge and released that day on bail, subject to certain no-contact conditions. Thereafter, Defendant allegedly assaulted the victim in Maine. Defendant was charged by complaint in Maine with, inter alia, violation of a protective order. Defendant filed a motion to dismiss the violation of a protective order count, asserting that the no-contact bail conditions ordered by the New Hampshire bail commissioner were not “similar” to a protective order for purposes of Maine statutes governing protection from abuse. The trial court granted Defendant’s motion to dismiss, and the State appealed. The Supreme Judicial Court remanded the matter to the trial court for further proceedings, holding that, on this record, the Court could not adequately address the issues raised by the parties. View "State v. Hederson" on Justia Law
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Criminal Law, Maine Supreme Judicial Court
State v. Kendall
After a jury trial, Defendant was convicted of three counts of theft by misapplication of property, one count of conspiracy to commit intentional evasion of tax, and three counts of failure to collect, account for, or pay over withholding tax. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions on the charges of theft by misapplication and failing to collect, account for, or pay over withholding taxes; and (2) the trial court did not abuse its discretion by admitting evidence of country club memberships purchased by a company Defendant owned and used exclusively with his wife. View "State v. Kendall" on Justia Law
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Criminal Law, Maine Supreme Judicial Court
State v. Westgate
After a jury trial, Defendant was found guilty of five counts of unlawful sexual contact and one count of visual sexual aggression against a child. At trial, the court did not require the jury to find one element of the crime - that the victim as younger than twelve when the sexual contact occurred - in order to deliver a guilty verdict. Defendant appealed, arguing that the trial court erred in instructing the jury that it did not need to determine when the offenses occurred. The Supreme Judicial Court vacated the judgment of conviction, holding (1) the trial court erred by not instructing the jury of the necessity of finding that the crimes were committed before the victim’s twelfth birthday; and (2) it cannot be concluded that it was highly probable that the error did not affect the jury’s verdict. Remanded. View "State v. Westgate" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Figueroa
Defendant entered a conditional guilty plea to the Class B charge of unlawful trafficking in scheduled drugs. Defendant appealed, challenging the denial of his motion to suppress statements he made during an interrogation. Specifically, Defendant argued that his statements made during the custodial interrogation must be suppressed because law enforcement did not specifically advise him that he had the right to the presence of counsel during questioning. The Supreme Judicial Court affirmed, holding that, under the circumstances of this case, Defendant was adequately advised of his constitutional right to counsel and that he effectively waived the privilege against self-incrimination, rendering his statements admissible against him at trial. View "State v. Figueroa" on Justia Law
State v. Jeskey
After a bench trial, Defendant was convicted of intentional or knowing murder and depraved indifference murder. The Supreme Judicial Court affirmed the judgment, holding (1) there was sufficient evidence to support the convictions; (2) the trial court did not err by concluding that Defendant failed to prove, by a preponderance of the evidence, that she was not guilty by reason of insanity; (3) the trial court did not err by not considering the “lesser included” offense of manslaughter; and (4) the court did not abuse its discretion by denying Defendant’s motion for a new trial on the basis of Defendant’s allegedly improved psychological state. View "State v. Jeskey" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court