Justia Criminal Law Opinion Summaries
Articles Posted in Maine Supreme Judicial Court
State v. Nightingale
The Supreme Judicial Court affirmed in all respects a judgment of conviction of two counts of murder and other weapons-related counts entered by the trial court following a jury trial on the murder charges and a bench trial on the other charges, holding that there was no error or abuse of discretion.Specifically, the Supreme Judicial Court held that the trial court (1) did not err by denying Defendant's request to present evidence to the jury that a State investigator had monitored telephone calls between Defendant and his attorney while Defendant was in pretrial detention; (2) did not err by giving a jury instruction on accomplice liability; (3) did not err by not granting a mistrial based on certain comments made by the prosecutor during the State's closing arguments; and (4) did not err in sentencing Defendant to life sentences on the murder charges. View "State v. Nightingale" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Lipscombe
The Supreme Judicial Court affirmed the judgment of conviction of hindering apprehension or prosecution entered by the trial court following a jury trial, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not commit obvious error in allowing a closing argument implying that Appellant had a burden of proving that the State's witnesses had a motive to lie and instructing the jury that it could "consider whether there has been any evidence introduced of any motive or lack of motive for a witness to exaggerate or lie"; and (2) the trial court did not abuse its discretion in denying Appellant's motion for voir dire of jurors filed after learning that one witness said “good luck” to the jurors while leaving the courtroom. View "State v. Lipscombe" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
Pratt v. State
The Supreme Judicial Court vacated the judgment of the trial court denying Petitioner's petition for post-conviction review (PCR) arguing that her trial counsel provided ineffective assistance, holding that Petitioner's conviction of domestic violence assault against her daughter must be vacated.In her PCR petition, Petitioner argued that trial counsel's representation was ineffective by opening the door during opening statements to prejudicial evidence about her parenting practices and because he did not object to prosecutorial error at trial. The PCR denied relief. The Supreme Judicial Court vacated the judgment below, holding that trial counsel's decision to open the door to evidence regarding Petitioner's parenting practices and his failure to object at trial to the prosecutorial error made his conviction unreliable and unworthy of confidence. View "Pratt v. State" on Justia Law
State v. Russell
The Supreme Judicial Court affirmed in part and vacated in part the judgment of the trial court convicting Defendant of gross sexual assault and four related crimes, holding that a specific unanimity instruction was necessary as to counts three and four.On appeal, Defendant argued that the trial court erred in not giving a specific unanimity instruction. The State conceded that a specific unanimity instruction was necessary as to counts three and four. The Supreme Court (1) vacated Defendant's convictions as to counts three and four; and (2) affirmed the judgment on but vacated Defendant's sentences imposed on counts one, two, and five because the sentences may have been affected by the now-vacated convictions on counts three and four. View "State v. Russell" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Norris
The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs and one count of unlawful trafficking in scheduled drugs and finding that $1,500 was subject to criminal forfeiture, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) Defendant's claim that his right to a speedy trial was violation under the Maine Constitution failed because he did not adequately assert his right, and his speedy trial claim under the United States Constitution failed under obvious error review; (2) Defendant's claim under the Maine Constitution that evidence obtained pursuant to the execution of a search warrant was inadmissible was unpreserved, and his claim under the United States Constitution that the warrants were not supported by probable cause failed; and (3) Defendant's last argument on appeal was unavailing. View "State v. Norris" on Justia Law
State v. Warner
The Supreme Judicial Court affirmed the trial court's judgment of conviction of unlawful sexual contact entered after a jury trial, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the prosecutor did not err in making statements during closing arguments stating that consideration of motive was important; (2) the trial court did not commit obvious error in instructing the jury regarding motive, the State's burden of proof, or the presumption of Appellant's innocence; and (3) the trial court did not commit obvious error in the way it handled the process of allowing the jurors to decide when to proceed with the trial after a potential COVID-19 exposure. View "State v. Warner" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Footman
The Supreme Judicial Court affirmed Defendant's conviction on charges of domestic violence aggravated assault and domestic violence assault and the trial court's finding of guilty on a charge of violating a condition of release, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the trial court violated his constitutional right to a representative jury by using the absolute disparity test to determine the racial makeup of the jury venire. The Supreme Judicial Court disagreed and affirmed, holding that the trial court (1) appropriately determined the 1.01% absolute disparity in Defendant's jury venire was insufficient to show underrepresentation; and (2) did not abuse its discretion in denying Defendant's motion to subpoena the grand jurors. View "State v. Footman" on Justia Law
State v. Brackett
The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of eluding an officer after a jury found him guilty of that offense and two misdemeanors, holding that the evidence rationally supported the jury's verdict.The jury returned a verdict finding Defendant guilty of all three charges for which he was indicted. Defendant moved for judgment of acquittal on the charge of eluding an officer, arguing that his speed was not reckless under the circumstances. The court granted the motion. The Supreme Judicial Court vacated the judgment of acquittal, holding that the jury could rationally find that Defendant operated at a "reckless rate of speed" - a required element of eluding an officer. View "State v. Brackett" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
Smith v. City of Sanford
The Supreme Judicial Court affirmed the judgment of the superior court in favor of the City of Sanford following a jury trial on Plaintiff's complaint alleging that the City discriminated against him because of his disability, in violation of the Maine Human Rights Act (MHRA), Me. Rev. Stat. 5, 4553-A(1)(A)(C)-(D), holding that there was no error in the proceedings below.On appeal, Plaintiff argued that the superior court erred in excluding his proposed jury instruction that "it is illegal as a matter of law for any employer to impose a 100% healed or 100% fit policy on any applicants for employment or any employees." The Supreme Court disagreed and affirmed, holding (1) Plaintiff properly preserved his objection to the court's instructions; and (2) the trial court did not err by rejecting Plaintiff's proposed instruction because it was sufficiently covered in the court's instructions. View "Smith v. City of Sanford" on Justia Law
Posted in:
Criminal Law, Maine Supreme Judicial Court
State v. Abdullahi
The Supreme Judicial Court affirmed Defendant's conviction of unlawful trafficking in scheduled drugs and falsifying physical evidence, entered after a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized as the result of what Defendant argued was an unlawful arrest; (2) there was no obvious error in the admission of lay opinion testimony by law enforcement officers on certain matters; (3) the record evidence was sufficient to justify the trial court's giving a permissible-inference instruction; and (4) there was no error or abuse of discretion in the denial of Defendant's motion for new trial and for judgment of acquittal. View "State v. Abdullahi" on Justia Law