Justia Criminal Law Opinion Summaries

In the case before the Maine Supreme Judicial Court, Dana A. Healey appealed his conviction for domestic violence assault. Healey argued that the trial court exceeded its discretion by not allowing him or his attorneys to conduct a voir dire examination of the jury and by denying his requests to cross-examine the victim about her recanted domestic violence allegation against another person and the text messages that she sent to Healey after his arrest. Healey contended that these rulings violated his constitutional rights to a jury trial and to confront witnesses against him.The court acknowledged Healey's concerns but ultimately affirmed the trial court's decision. The court found that the trial court did not abuse its discretion when it denied Healey’s request to cross-examine the victim about her recanting a domestic violence allegation against another person. The court also found that the trial court erred in excluding at least one of the victim’s text messages to Healey: the message stating, “We’re even.” However, the court determined that, despite this error, there was sufficient, independent evidence to support the jury's verdict.The court based its decision on the testimony of the responding officer and a witness who saw the incident, as well as the 9-1-1 call made by the witness. These pieces of evidence, the court concluded, provided sufficient support for the jury's verdict, regardless of the excluded text messages. Therefore, the court was satisfied beyond a reasonable doubt that the excluded evidence would not have affected the jury's verdict. As such, the court affirmed Healey's conviction and sentence. View "State of Maine v. Dana A. Healey" on Justia Law

In the case before the Maine Supreme Judicial Court, Taylor A. Pelletier was convicted of multiple crimes, including two counts of kidnapping with a dangerous weapon, two counts of aggravated assault, one count of domestic violence threatening with a dangerous weapon, and one count of domestic violence terrorizing with a dangerous weapon. The trial court found Pelletier guilty based on evidence from a home security system and the victim's testimony, which the court found credible.Pelletier appealed his conviction, raising three main issues: the sufficiency of the evidence supporting his kidnapping conviction, the sufficiency of the indictment for the first count of kidnapping, and the trial court's denial of his motion to dismiss for alleged discovery and Brady violations.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court found that the evidence was sufficient to support the kidnapping conviction. The court held that Pelletier had confined the victim inside the house for a substantial period, which went beyond the time necessary to commit the assaults. The court also found that the indictment adequately stated the charges against Pelletier, giving him sufficient notice to prepare his defense. Lastly, the court held that the trial court did not abuse its discretion in denying Pelletier's motion to dismiss for discovery and Brady violations. The court held that the trial court's sanction of a continuance was sufficient to mitigate any prejudice caused by the State's late disclosure of evidence. View "Maine v. Pelletier" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court for attempted murder and other crimes with respect to Defendant's contended errors but vacated Defendant's sentences with respect to domestic violence assault and domestic violence terrorizing, holding that those sentences exceeded the maximum allowable under Me. Rev. Stat. 17-A, 1604(1)(D).On appeal, Defendant argued that the trial court abused its discretion by imposing a discovery sanction under M.R.U. Crim. P. 16(e) and that the jury venire was not drawn from a fair cross-section of the community. The Supreme Judicial Court affirmed the convictions but vacated the sentences in part, holding (1) the trial court's discovery sanction constituted a fundamentally fair balance between the parties' competing interests; (2) Defendant did not sufficiently preserve or present a sufficient record for the Supreme Court to reach Defendant's second contention; and (3) the trial court erred by entering a one-year sentence for Defendant's convictions for domestic violence assault and domestic violence, both class D misdemeanors. View "State v. Page" on Justia Law

The Court of Appeals affirmed the judgment of default and forfeiture of $17,815 in cash bail entered after the trial court denied Defendant's motion to set aside the forfeiture of that portion of his deposited cash bail, holding that the trial court did not abuse its discretion in denying Defendant's motion to set aside the forfeiture.On appeal, Defendant argued that the trial court abused its discretion in denying his motion because the bail bond did not explicitly warn him of forfeiture as a potential consequence for violating the condition of his release that he commit no violation of a bail condition. The Court of Appeals affirmed, holding that, on the record, the trial court did not abuse its discretion in denying Defendant's motion as to $17,815 of his deposited cash bail. View "State v. Covington" on Justia Law

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

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

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

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

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

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