Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of murder but vacated his sentence, holding that a criminal defendant's decision to exercise his constitutional right to a trial by jury may not be considered at sentencing.After a seven-day trial at which Defendant did not testify, the jury returned a verdict of guilty to murder. After a sentencing hearing, the court found that there were no mitigating circumstances and imposed a thirty-two-year sentence. The Supreme Judicial Court vacated Defendant's sentence, holding that the trial court (1) did not err when it denied Defendant's request to provide him with access to the grand jury transcript; but (2) abused its discretion by referencing Defendant's demand for a jury trial in determining the genuineness of Defendant's claim of personal reform and contrition. View "State v. Moore" on Justia Law

The Supreme Judicial Court affirmed the judgment convicting Defendant of two counts of gross sexual assault, holding that the trial court did not err in determining that Defendant was an "other official" under Me. Rev. Stat. 17-A 253(2)(F).Defendant was a fifty-seven-year old driving school owner who taught driver's education courses at a public high school in Skowhegan. On two occasions, Defendant picked up the victim at school in the vehicle that he used to teach students to drive, drove her to a motel, and engaged in a "sexual act" with the victim. The State charged Defendant with two counts of gross sexual assault under section 253(2)(F), under which a person is guilty if he engages in a sexual act with a student and the actor is a "teacher, employee or other official having instructional, supervisory or disciplinary authority over the student." The trial court concluded that Defendant was an "other official" of the high school and convicted him of both charges. The Supreme Judicial Court affirmed, holding that the evidence was sufficient to support the lower court's findings. View "State v. Marquis" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court dismissing Plaintiff's claims for abuse of process and wrongful use of civil proceedings, holding that the trial court erred in dismissing Plaintiff's claim for wrongful use of civil proceedings.Plaintiff sued three New York-based dentists and their dental practice (collectively, Defendants) asserting claims for abuse of process, wrongful use of civil proceedings, and punitive damages. Defendants filed a motion to dismiss for failure to state a claim pursuant to Me. R. Civ. P. 12(b)(6). The trial court granted the motion. The Supreme Judicial Court reversed in part, holding that Plaintiff's complaint stated a claim for wrongful use of civil proceedings but not for abuse of process. View "Leighton v. Lowenberg" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered upon Defendant's conditional guilty plea after the trial court denied his motion to suppress evidence obtained through a police officer's interactions with him in a convenience store parking lot, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant moved on multiple grounds to suppress evidence obtained as a result of his interactions with the police officer, arguing that he was unlawfully seized based on an unreliable anonymous tip and was directed to perform field sobriety testing without given a chance to decline. The court denied the motion to suppress. Defendant then entered a conditional guilty plea to operating under the influence. The Supreme Judicial Court affirmed, holding that the officer did not violate the United States Constitution by conducting field sobriety tests under the circumstances of this case. View "State v. Wilcox" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for two counts of intentional or knowing murder but vacated Defendant's two concurrent life sentences and remanded the case for resentencing, holding that Defendant's sentences were improper.Specifically, the Supreme Judicial Court held that the trial court (1) committed harmless error in admitting evidence of the victim's intention to seek a protection order against Defendant; (2) did not commit obvious error by not, sua sponte, striking the prosecutorial argument in closing implying that Defendant had a burden of proof or by not delivering a limiting instruction; and (3) erred by improperly taking domestic violence into account when setting the basic term of imprisonment for the crimes because a consideration of domestic violence belongs only in the second step of the sentencing process when the court weighs aggravating and mitigating factors. View "State v. Penley" on Justia Law

The Supreme Judicial Court affirmed the final judgment and order of the district court in Husband's divorce from Wife and imposed sanctions, holding that Husband's appeal was frivolous and contumacious within the meaning of M. R. App. P. 13(f).On appeal, Husband contended that the trial court both violated his rights to due process by failing to hold a trial and made impermissible changes to the parties' mediation agreement. The Supreme Judicial Court affirmed, holding (1) there was no violation of Defendant's due process rights; (2) the final divorce judgment accurately incorporated the terms of the parties' agreement; and (3) Husband should be sanctioned for this frivolous and contumacious appeal. View "Aubuchon v. Blaisdell" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of stalking, violation of a protective order, and violation of a condition of release, holding that the trial court did not err or abuse its discretion in allowing the victim to identify Defendant as the individual who was telephoning her and threatening her.The victim was a female human resources staffer who terminated Defendant's employment. On appeal, Defendant argued that the trial court abused its discretion in allowing the victim to testify that Defendant was the person who was telephoning the victim because her lay opinion testimony lacked the foundational requirements for admission. The Supreme Judicial Court affirmed, holding that the trial court's allowance of the victim's testimony identifying Defendant as the caller was neither unlawful nor an abuse of discretion. View "State v. Gibb" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for gross sexual assault but remanded for the court to determine the appropriate length and conditions of supervised release to be imposed, holding that there was otherwise no error.Specifically, the Supreme Judicial Court held (1) because a principal and accomplice are not subject to different processes or analyses when a sentencing court applies the Hewey analysis set out in Me. Rev. Stat. 17-A, 1602, the sentencing court did not err when it set the basic sentence at twenty years in compliance with Me. Rev. Stat. 17A-1252(4-E); and (2) remand was required for the district court to determine the length and conditions of supervised release to be imposed and to articulate its analysis and the factors that led to its decision. View "State v. Ringuette" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of, among other charges, seventeen counts of sexual exploitation of a minor under the age of twelve, holding that a search of Defendant's smartphone did not violate Defendant's rights under the Fourth Amendment.On appeal, Defendant argued that the trial court abused its discretion when it declined to reach its argument that the warrant supporting the search of his cellphone was overbroad and violated the particularity requirement of the Fourth Amendment. The Supreme Judicial Court disagreed and affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress; and (2) Defendant's remaining arguments on appeal were without merit. View "Maine v. Jandreaud" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for attempted murder, aggravated assault, and other crimes following a nonjury trial, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court failed adequately to consider the evidence that he was suffering from a serious mental abnormality and that there was insufficient evidence to prove intent beyond a reasonable doubt. The Supreme Judicial Court agreed and affirmed, holding (1) the evidence supported the trial court's finding that Defendant was not suffering from an abnormal condition of the mind that raised a reasonable doubt as to whether he acted intentionally when he shot the victim; and (2) the court did not err in finding that Defendant failed to meet his burden of proof on his affirmative insanity defense. View "State v. Hallowell" on Justia Law