Justia Criminal Law Opinion Summaries
Articles Posted in Maine Supreme Judicial Court
State v. Mahmoud
After a jury trial, Defendant was convicted of one count of assault. Defendant appealed, asserting that the superior court committed prejudicial error by failing to give his proposed jury instructions on eyewitness identification. The court did give an instruction on eyewitness identification but did not give Defendant’s proposed instructions verbatim. The Supreme Judicial Court affirmed, holding (1) the jury instructions that the trial court gave were a correct statement of the law; (2) the requested instruction was not generated by the evidence; and (3) the requested instruction was sufficiently covered by the instructions given. View "State v. Mahmoud" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Arbour
After a jury trial, Defendant was convicted of multiple drug offenses. The Supreme Judicial Court affirmed, holding (1) the suppression court did not err by denying Defendant’s motion to suppress evidence seized from his apartment pursuant to a search warrant, as there was a substantial basis for the finding of probable cause to issue the search warrant; (2) the suppression court did not err by denying Defendant’s motion to suppress a statement he made in the interview room at the police department before receiving Miranda warnings, as Defendant was not subject to interrogation at the time he made his statement; and (3) the evidence of drug quantity at trial was sufficient to support Defendant’s conviction for aggravating trafficking of heroin. View "State v. Arbour" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Knight
Defendant pleaded guilty in the trial court to a number of burglaries and thefts committed from nearby residences in the woods near Rome. When Defendant was sentenced, he paid almost an entire agreed amount of restitution for the victims of the burglaries and thefts. In addition, the court ordered Defendant to pay $1,125 to the Maine State Police (MSP) for expenses it incurred when it repaired a woods road it used during the criminal investigation. The Supreme Judicial Court vacated the order of restitution but affirmed the remaining aspects of the judgment of conviction and the related sentence, holding that, under the circumstances of this case, the MSP was not a statutorily eligible recipient of restitution. View "State v. Knight" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
Torres v. Department of Corrections
Plaintiff, an inmate, filed a petition for judicial review of a Department of Corrections' decision finding him guilty of the disciplinary offense of tattooing. The superior court dismissed Plaintiff’s petition for failure to pay the initial partial filing fee. Plaintiff’s appealed, arguing that because he had no funds with which to pay the initial partial filing fee, the court abused its discretion in dismissing the action for failure to prosecute. The Supreme Judicial Court vacated the order dismissing the petition, holding that the court abused its discretion by dismissing the case without making a finding as to Plaintiff’s ability to pay. Remanded. View "Torres v. Department of Corrections" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Palmer
Defendant was charged with two criminal counts. Defendant consented to a deferred disposition in the district court and pleaded guilty to endangering the welfare of a child. Following a hearing on the final disposition, the district court stated that the deferred disposition was “unsuccessful” and imposed a sentencing alternative. Defendant appealed, arguing that the court erred by finding that she inexcusably failed to comply with a term of her agreement based on the State’s argument that Defendant did not complete a psychological evaluation that focused on parenting. The Supreme Court vacated the judgment, holding that the court erred in finding that Defendant inexcusably failed to comply with the psychological evaluation requirement of the deferred disposition. Remanded. View "State v. Palmer" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Carton
Defendants, two cousins, were convicted of unlawful trafficking in scheduled drugs. Defendants appealed, challenging the trial court’s denial of their motion to suppress evidence obtained during a warrantless search and during police questioning. The Supreme Court affirmed, holding (1) the court did not err in concluding that the warrantless search was valid because neither of the defendants affirmatively denied the officer consent to conduct the search; and (2) the court did not err in concluding that one of the defendant’s statements made while he was in custody but before he was informed of his Miranda rights was admissible under the public safety exception to Miranda. View "State v. Carton" on Justia Law
State v. Poulin
After a jury trial, Defendant was convicted of murder and arson. Defendant was sentenced to life imprisonment for the murder. During the proceedings, the trial court excluded GPS data and handwritten notes from the State’s case-in-chief due to hearsay problems or discovery violations. The court, however, stated that it would revisit its ruling regarding the admissibility of the evidence should it be necessary for impeachment purposes. On appeal, Defendant argued that the trial court’s evidentiary rulings violated his right to a fair trial by preventing him from presenting evidence contrary to the facts indicated in the excluded evidence. The Supreme Judicial Court affirmed, holding that the court’s rulings excluding the evidence at issue from use in the State’s case-in-chief were not an abuse of discretion and did not violate Defendant’s constitutionally guaranteed right to a fair trial. View "State v. Poulin" on Justia Law
State v. Simmons
The two defendants in this case - James Simmons and Frederick Campbell - were each charged with and indicted for two counts of arson. Simmons filed a motion to suppress the evidence seized as a result of search warrants, arguing that the search warrants were not supported by probable cause. The superior court granted the motion and suppressed evidence of cellular telephone records seized pursuant to the warrants. The Supreme Judicial Court vacated in part and affirmed in part, holding (1) the affidavits established probable cause for the State to seize those portions of Simmons’s cell phone records relating to historical cell site location data for a certain day; and (2) the remaining aspects of the suppression order as to Simmons and the order in its entirety as to Campbell were without error. View "State v. Simmons" on Justia Law
State v. Daluz
After a jury trial, Defendant was convicted of three counts of murder. Defendant filed a motion for a new trial, arguing that he had been deprived of due process by being tried jointly with his co-defendant and by statements made by his co-defendant’s counsel. Specifically, he argued that his co-defendant’s counsel had impermissibly commented upon Defendant’s decision not to testify and his race. After a hearing, the trial court denied the motion for a new trial. The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion for a new trial, holding (1) the court did not abuse its discretion by denying Defendant’s motion to sever his trial from his co-defendant’s; (2) the trial court did not abuse its discretion when it denied Defendant’s motion for a new trial as to the silence-related comments; and (3) the trial court properly determined that three race-related comments were improper but that the comments had not affected Defendant’s substantial rights. View "State v. Daluz" on Justia Law
State v. Sasso
Defendant entered a conditional plea of nolo contendere to the crime of operating after suspension. A judgment of conviction was entered accordingly. Defendant appealed, arguing that the lower court erred in denying his motion to suppress because the law enforcement officer’s decision to stop his vehicle was pretextual and the stop was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding that the record supported the court’s inferred finding that the stop was supported by a reasonable articulable suspicion of a threat to public safety, and therefore, the lower court did not err in denying Defendant’s motion to suppress. View "State v. Sasso" on Justia Law