Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of criminal threatening. Before trial, Defendant filed a motion to suppress statements he had made after police officers stopped his vehicle, took his license and registration, and asked him to wait for a detective to arrive. The suppression court granted the motion in part but denied it as to the statements Defendant made before he was placed in handcuffs and arrested, holding that Defendant was not in custody until he was placed in handcuffs and that after he was handcuffed he did not waive his Miranda rights. Defendant appealed, arguing that the trial court erred by declining to suppress the statements that he made to the detective before his formal arrest. The Supreme Court vacated the judgment of conviction and vacated the suppression order in part, holding that Defendant was in custody when he responded to the detective’s questions and accusations, and because he was in custody when he made incriminating statements without the benefit of Miranda warnings, those statements were improperly admitted at trial. Remanded. View "State v. King" on Justia Law

In 2014, Defendant entered a conditional guilty plea to operating under the influence (OUI), elevated to a Class C felony by two prior convictions for operating under the influence. Defendant appealed, asserting that his 2013 OUI conviction - one of the two convictions that enhanced his 2014 charge - was obtained in violation of his Sixth Amendment right to counsel, and therefore, the trial court erred in denying his motion to strike that conviction from the indictment. The Supreme Judicial Court affirmed, holding that Defendant failed to meet his burden on collateral attack of demonstrating that he did not knowingly and intelligently waive his right to counsel. View "State v. Kennedy" on Justia Law

After a jury trial, Defendant was convicted of kidnapping and murdering a fifteen-year-old girl. The Supreme Judicial Court affirmed, holding (1) the trial court did not err by admitting nonexpert opinion testimony regarding handwriting to prove that Defendant wrote a document admitting to the crime, and even if the admission of the testimony was in error, it is highly probable that any error would have been harmless; and (2) there was no error, much less an error so prejudicial that it deprived Defendant of his right to a fair trial, in the State’s repeated mention of the jurors’ “common sense” in its closing argument. View "State v. Dube" on Justia Law

Defendant entered a conditional guilty plea to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained from the stop of his vehicle by a game warden. The suppression court found that the warden stopped Defendant’s vehicle after making an “unnecessarily wide” right turn into the approaching lane of another road. The Supreme Court affirmed, holding that the warden’s testimony was sufficient to support the suppression court’s finding that the warden had a reasonable articulable suspicion that Defendant had committed a traffic violation and that the warden’s subjective suspicion was objectively reasonable under the circumstances. View "State v. Simmons" on Justia Law

After a jury trial, Appellant was convicted of one count of gross sexual assault and three counts of endangering the welfare of a child. Appellant appealed, arguing that the trial court erred in excluding a licensed counselor’s proposed testimony concerning Appellant’s experience of abuse and its effect on her decision-making, as the testimony was relevant to the defense of involuntary conduct. The Supreme Court affirmed, holding that the trial court did not err in determining that the counselor’s background and his expected testimony regarding Appellant’s history of being abused was not relevant to the defense of involuntariness. View "State v. Morrison" on Justia Law

Appellant was charged with improperly accepting more than $109,003 in benefits from MaineCare by misrepresenting the composition of her household. After a jury-waived trial, Appellant was convicted of one count of theft by deception. Appellant appealed, arguing that the State did not prove beyond a reasonable doubt that her deception resulted in the taking of the property of another and that the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding that there was sufficient evidence to find that Appellant committed theft by deception when she intentionally misrepresented that her two minor children lived with her fifty percent or more of the time. View "State v. Hodsdon" on Justia Law

After a jury trial, Defendant was convicted of two counts of criminal restraint by a parent. Defendant appealed, asserting that the trial court erred by failing to declare a mistrial sua sponte after Defendant’s mother testified that she had visited Defendant in jail. Specifically, Defendant argued that the testimony undermined the fairness of the fact finding process by creating an impression in the jurors’ minds of Defendant’s guilt. The Supreme Court affirmed the conviction, holding that Defendant’s mother’s brief statement at trial likely did not have any effect, much less a prejudicial effect, on Defendant’s right to a fair trial. View "State v. Retamozzo" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer. Defendant appealed, arguing that the trial court erred in finding that the State had met its burden to demonstrate the corpus delicti to allow the admission of evidence of Defendant’s out-of-court incriminating statements. The Supreme Judicial Court affirmed, holding that the trial court did not err when it concluded that the State had presented sufficient evidence to support a substantial belief that someone had stolen a package sent to the victim and, on that basis, admitted evidence of Defendant’s out-of-court inculpatory statements. View "State v. Poulin" on Justia Law

In 2008, Defendant pleaded guilty to theft, and in 2009, Defendant pleaded guilty to trafficking in a schedule Z drug. Defendant was ordered to pay fines in both cases. In 2014, Defendant was arrested for nonpayment of the fines. Defendant was subsequently committed to jail pursuant to Me. Rev. Stat. 17-A 1304(3) for intentionally or knowingly refusing to pay the fines assessed against him. Defendant appealed. The Supreme Judicial Court dismissed the appeal because the section 1304 hearing was a post-conviction proceeding, and Defendant’s sole avenue for appeal was through post-conviction review in the superior court. View "State v. Hayes" on Justia Law

After a jury-waived trial, Defendant was convicted of murder for causing the death of her two-year-old daughter by giving her a large dose of Benadryl and then physically suffocating her. Defendant appealed, arguing that the trial court erred by finding that she did not prove her affirmative defense that she was not criminally responsible by reason of a mental disease or defect and by finding that her actions in killing her daughter were intentional or knowing. The Supreme Judicial Court affirmed, holding (1) the record supports the court’s finding that Defendant did not prove her affirmative defense of not criminally responsible by reason of a mental disease or defect; and (2) the record supports the trial court’s finding that Defendant intentionally or knowingly caused her daughter’s death. View "State v. Norris" on Justia Law