Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of one count of gross sexual assault and fifteen counts of unlawful sexual contact. Defendant later filed a petition for post-conviction review, claiming that trial counsel was ineffective by failing to seek a continuance of the sentencing hearing when Defendant was allegedly incompetent and was unable to exercise his right of allocution due to his emotional state. The court denied the petition. The Supreme Judicial Court affirmed, holding that the evidence did not compel the court to find that Defendant was deprived of constitutionally effective assistance when his trial counsel proceeded with, rather than sought to continue, the sentencing hearing despite Defendant’s confused and emotional state. View "Middleton v. State" on Justia Law

After a nonjury trial, Defendant was convicted of operating under the influence (OUI) enhanced with one prior OUI conviction. Defendant appealed, arguing, among other things, that the trial court erred by allowing the arresting officer to testify about Defendant’s statements and the officer’s observations indicating Defendant’s impairment from drugs other than alcohol because the officer lacked sufficient training or expertise in drug impairment recognition and could not perform certain evaluations that a drug recognition expert could have. The Supreme Court affirmed, holding (1) any deficiencies in an officer’s training or expertise goes to the weight, but not the admissibility, of the officer’s testimony regarding observations of impairment; and (2) the trial court in this case did not err in admitting the arresting officer’s testimony regarding his observations and the results of the field sobriety tests, as the officer was qualified to testify as to his observations, that evidence was relevant to the OUI charge, and its admission was not otherwise barred. View "State v. Atkins" on Justia Law

Defendant entered a conditional plea of nolo contendere to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained as a result of a stop of his vehicle and after his subsequent arrest and Intoxilyzer test. The Supreme Judicial Court affirmed, holding (1) the court did not err in concluding that the traffic stop was based on reasonable articulable suspicion; and (2) the evidence was sufficient to establish that the law enforcement officer had probable cause to arrest Defendant and subject him to an Intoxilyzer test. View "State v. Morrison" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence. Defendant was sentenced to four days in jail, an $800 fine, and a ninety-day license suspension. Defendant appealed, arguing that the evidence presented at trial was insufficient to support his conviction because no rational jury could find that he operated or attempted to operate his vehicle. The Supreme Court affirmed, holding that the evidence was sufficient to support the conviction, as a rational jury could have found, beyond a reasonable doubt, that Defendant, while impaired, either drove his car to its resting place or attempted to drive his car after a law enforcement officer woke him up. View "State v. Belhumeur" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer. The Supreme Court affirmed the judgment of conviction, holding (1) the evidence was sufficient to support the theft conviction; (2) the trial court did not err in admitting into evidence several emails between Defendant and representatives of the named victims; (3) no advice-of-counsel instruction should have been given, and any error in the actual instruction given was harmless; (4) the trial court did not err in denying Defendant’s motion for a bill of particulars; and (5) the indictment in this case was not duplicitous and was properly charged. View "State v. Flynn" on Justia Law

After a bench trial, Defendant was convicted of crimes stemming from his alleged illegal possession of digital images and videos depicting the sexual assault or exploitation of children. Defendant appealed, arguing that there was insufficient evidence to sustain the convictions for two counts of possession of sexually explicit material. The Supreme Court affirmed, holding that, given the evidence presented at trial, and applying the plain meaning of the statute in effect at the time of the crimes, the trial court’s findings were supported by competent evidence in the record, and the facts supported the court’s finding of guilt beyond a reasonable doubt. View "State v. Wilson" on Justia Law

Defendant was charged with criminal operating under the influence. Defendant moved to suppress the evidence of his roadside interactions with a game warden from the moment the game warden parked his marked patrol vehicle behind Defendant’s stopped truck, exited the vehicle, and said, “Hi. Game warden.” The trial court denied the motion to suppress, concluding that the warden did not effect a Terry stop, and therefore, Defendant was not seized within the meaning of the Fourth Amendment prior to the moment the warden observed signs of Defendant’s intoxication. The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress, holding that Defendant was not seized at any time before the warden observed signs of Defendant’s intoxication. View "State v. Ciomei" on Justia Law

After a jury-waived trial, Defendant was convicted of aggravated assault and domestic violence assault. Defendant appealed, contending that the evidence was insufficient to support his conviction for aggravated assault. Specifically, Defendant argued that a strangulation incident did not support the finding that he assaulted the victim under circumstances manifesting extreme indifference to the value of human life. The Supreme Judicial Court affirmed, holding that the victim’s testimony supported the court’s finding that Defendant applied enough force to the victim’s neck to impede her breathing, and therefore, the evidence was sufficient to support Defendant’s conviction for aggravated assault. View "State v. Saucier" on Justia Law

After a jury trial, Defendant was convicted of one count of unlawful sexual assault. Defendant later filed a petition for post-conviction review, alleging that his trial counsel failed to provide effective representation during the pretrial and trial proceedings. After a hearing, the superior court denied Defendant’s petition based on its conclusion that Defendant failed to establish that he was “actually prejudiced by any such deficiencies.” The Supreme Judicial Court vacated the post-conviction judgment and remanded for reconsideration, holding that the superior court’s decision applied a test for prejudice that did not fully implement the proper standard of prejudice established in Strickland v. Washington. View "Theriault v. State" on Justia Law

After a nonjury trial, the trial court convicted Defendant of operating while his license was suspended or revoked and sentenced him to thirty days in jail. Defendant appealed, arguing that the trial court did not have jurisdiction to enforce the laws of the “State of Maine” against him and that Maine’s law requiring each driver to hold a valid driver’s license is facially unconstitutional because it violates a purported fundamental right to travel. The Supreme Judicial Court affirmed, holding (1) state jurisdiction over an individual extends to those present within the physical bounds of the state; and (2) the state may, as a valid exercise of its police power, place limitations on the operation of motor vehicles on the state’s roads. View "State v. Pelletier" on Justia Law