Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of robbery. Defendant proceeded to trial without representation after the trial court determined that Defendant had forfeited his right to counsel after threatening to cause serious bodily harm to one of his attorneys in the presence of another attorney, by his deliberate unwillingness to work with those attorneys’ predecessors, and by failing to show that he would work cooperatively with successor counsel. The Supreme Judicial Court affirmed the trial court’s decision to require Defendant to proceed to trial without legal representation, holding (1) in circumstances of egregious misconduct, an accused can forfeit his right to counsel, and in this case, the trial court did not err in concluding that Defendant’s conduct rose to the level that constituted a forfeiture; and (2) in the alternative, the record established that through his egregious misconduct, Defendant waived his right to counsel by implication. View "State v. Nisbet" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence and violating a condition of release. Defendant was sentenced to a term of sevens days in county jail. On appeal, Defendant argued that the trial court erred in denying his motion to suppress and, at trial, in admitting evidence of his blood-alcohol level derived from a sample of his blood that was seized without a search warrant. The Supreme Judicial Court affirmed, holding that the trial court did not err in denying the motion to suppress, as there were exigent circumstances at the time of the blood draw negating the requirement for a search warrant. View "State v. Arndt" on Justia Law

Defendant was found guilty of aggravated trafficking of a schedule W drug, a Class A crime, for selling a single strip of Suboxone to a confidential informant. The trial court sentenced defendant to eight years in prison. Defendant appealed, arguing that the State failed to present evidence that Suboxone is a drug that falls within one of the listed categories of schedule W drugs. The Supreme Judicial Court held that because the State failed to establish that Suboxone was, in fact, a schedule W drug - evidence that is required for purposes of proving the charged Class A crime - the conviction must be vacated. Remanded for the entry of a judgment of acquittal. View "State v. Sudsbury" on Justia Law

After a jury trial, Defendant was convicted of murder. Defendant was sentenced to a term of fifty-five years in prison and ordered to pay restitution to the State Victims’ Compensation Fund. Defendant subsequently filed a motion for a new trial, arguing that the evidence was insufficient to support the conviction and that the prosecutor engaged in impermissible misconduct during trial. The trial court denied Defendant’s motion for a new trial. The Supreme Court affirmed, holding (1) the court did not err in denying Defendant’s motion for a new trial based on its finding that the verdict was, to a high probability, not affected by the prosecutor’s misconduct; and (2) the trial court did not err in its responses to the jury’s request for a review of testimony. View "State v. Robinson" on Justia Law

After a jury trial, Defendant was convicted of one count of Class B unlawful sexual contact and two counts of Class C unlawful sexual contact. Defendant appealed, arguing that his conviction on the Class B charge should be vacated because the proof at trial varied from the dates alleged in the indictment and, therefore, his constitutional right to be protected from double jeopardy was implicated. The Supreme Judicial Court affirmed, holding that the variance between the indictment and the evidence presented at trial did not violate Defendant’s right to protection from double jeopardy and did not defeat the conviction for the Class B charge of unlawful sexual contact. View "State v. Lyon" on Justia Law

Defendant was convicted of failing to label an observation stand. Defendant appealed, arguing that the State was equitably estopped from prosecuting him because, when he purchased his hunting license, he was given a magazine endorsed by the Maine Department of Inland Fisheries and Wildlife (IF&W) that misstated the law concerning tree stands. The Supreme Court affirmed, holding that Defendant failed to prove that IF&W made any misrepresentation in its publication that Defendant relied upon to his detriment, and therefore, the trial court correctly determined that the single source of controlling law was the statute duly enacted by the Legislature. View "State v. Austin" on Justia Law

After a jury trial, Defendant was convicted of attempted murder and related crimes. Before trial, Defendant moved for a change of venue on the ground that the pretrial publicity surrounding the case was so prejudicial that selecting the jury would be “an exercise in futility.” The court deferred ruling on the motion before the jury was impaneled. The jury was subsequently impaneled, and Defendant did not renew his motion for change of venue at any point in the proceedings. The Supreme Judicial Court affirmed, holding (1) the superior court did not err by declining to change the trial venue based on pretrial publicity, as there was no basis for the court to find that Defendant could not receive a fair trial in that venue; and (2) the evidence was sufficient to support the convictions. View "State v. Black" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault. Defendant appealed, arguing that a statement made by the prosecutor during closing argument constituted prosecutorial misconduct that deprived him of a fair trial, that the court’s jury instruction on self-defense was erroneous, and that the evidence was insufficient to support his conviction. The Supreme Judicial Court affirmed, holding (1) the prosecutor’s statement did not constitute misconduct; (2) the court’s instructions were internally consistent and legally accurate; and (3) the evidence was sufficient to support Defendant’s conviction. View "State v. Weaver" on Justia Law

After a jury trial, Defendant was convicted of domestic violence assault with prior convictions. Defendant appealed, arguing that there was insufficient evidence to convict him of domestic violence assault. Specifically, Defendant argued that the State did not prove beyond a reasonable double that he and the victim were “sexual partners,” which is an element of the offense. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support the finding that Defendant and the victim were or had been “sexual partners,” and thus were “family or household members,” which is an element of the offense. View "State v. Murphy" on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to forty-two years’ imprisonment. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in admitting into evidence an audio recording of Defendant’s interview with a police detective, as its admission did not violate Me. R. Evid. 802 and 403, did not allow improper prosecutorial vouching, and did not result in prejudice; and (2) the trial court did not err in admitting evidence that Defendant had assaulted the victim hours before she was killed, as the evidence’s admission did not violate Rule 403, and the court’s limiting instruction was sufficient to satisfy Mont. R. Evid. 404(b). View "State v. Pratt" on Justia Law