Justia Criminal Law Opinion Summaries

The Supreme Judicial Court vacated the judgment of conviction of attempted murder and other offenses entered by the trial court, holding that multiple acts of prosecutorial error occurred in this case, requiring remand for a new trial.A jury found Defendant guilty of attempted murder, elevated aggravated assault, robbery, and reckless conduct with a dangerous weapon. On appeal, Defendant principally argued that the trial court erred in denying his repeated motions for a mistrial based on allegedly improper comments made during the prosecution's opening statement, closing statement, and rebuttal. The Supreme Judicial Court agreed and remanded the case for a new trial, holding (1) the State committed error in its opening statement and closing argument; and (2) because Defendant's substantial rights were impaired, under Me. Const. art. I, 6 and 6-A and this Court's supervisory power, the appropriate remedy in this case was a new trial. View "State v. White" on Justia Law

The Supreme Court vacated the judgment of the trial court convicting Defendant on two charges of aggravated furnishing of cocaine, which were merged for sentencing, holding that the trial court erred when it denied Defendant's motion to suppress, and the error was not harmless.At issue was the denial of Defendant's motion to suppress evidence obtained when police officers stopped him after receiving an anonymous tip and searched his belongings outside a bus station. The trial court concluded that the officers had an objectively reasonable, articulable suspicion that Defendant had been engaged in criminal activity when they stopped they stopped him. The Supreme Court vacated the judgment below, holding that the evidence regarding the anonymous tip and the police's efforts to confirm its reliable failed to establish an objectively reasonable, articulable suspicion sufficient to justify the stop. View "State v. Barclift" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered in the trial court upon his conditional guilty plea to drug-related offenses and endangering the welfare of a child, holding that the trial court did not err when it denied Defendant's motion to suppress.Based on evidence discovered during the stop of a Honda Civic the grand jury indicted Defendant on the four counts for which he was later convicted. Defendant moved to suppress the evidence obtained during the stop, arguing that the police officer lacked a clearly articulated and objectively reasonable suspicion to justify the seizure. The trial court denied the motion to suppress, and Defendant entered conditional guilty pleas on all counts. The Supreme Judicial Court affirmed, holding that the vehicle stop was constitutionally permissible, and therefore, the trial court did not err in denying Defendant's motion to suppress. View "State v. Lovell" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction of criminal operating under the influence (OUI) with one previous OUI offense and violation of condition of release entered by the trial court after a jury trial but vacated Defendant's sentence, holding that remand was required for resentencing.On appeal, Defendant argued, among other things, that the trial court abused its discretion by admitting his breath test results and that his right to confrontation was violated by the admission of the breath test certificate. The Supreme Judicial Court disagreed with Defendant's convictions and affirmed the judgment. The Court, however, vacated Defendant's sentence, holding that his sentence did not meet the mandatory minimum requirements for a conviction of criminal OUI with one previous OUI offense. View "State v. Beeler" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of aggravated trafficking of scheduled drugs, holding that the trial court did not err in denying Defendant's motion to suppress, and Defendant's remaining allegations of error were unavailing.Specifically, the Supreme Judicial Court held (1) because law enforcement had probable cause to arrest Defendant, the court did not err in denying Defendant's motion to suppress; (2) the trial court did not err in determining that there was no violation of the court's sequestration order; (3) there was no obvious error in the instructions given to the jury; and (4) there was no illegality in the sentence or in the court's procedure. View "State v. Rosario" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder and his sentence of fifty years in prison, holding that there was no error or abuse of discretion.At issue on appeal was whether the trial court erred in denying Defendant's motion to suppress his statements to law enforcement while walking them through his home. The Supreme Judicial Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant's motion to suppress a video recording of a walk-through of the crime scene, as there was no police misconduct in the interviews and walk-through with Defendant; (2) did not err in denying Defendant's motion for judgment of acquittal; (3) did not commit obvious error in not instructing the jury on concurrent causation; and (4) did not misapply legal principles or abuse its sentencing power in setting the basic sentence. View "State v. Athayde" on Justia Law

The Supreme Judicial Court affirmed the judgment entered by the district court extending a weapons restriction placed on J because J presented a likelihood of foreseeable harm, holding that there was no error in the proceedings below.While J was in protective custody for threatening behavior a doctor concluded that J was a mentally ill person within the meaning of Me. Rev. Stat. 34-B, 3801(5) and that he posed a likelihood of foreseeable harm within the meaning of Me. Rev. Stat. 34-B, 3862-A. The court subsequently prohibited J from possessing dangerous weapons pending a judicial hearing. After a hearing, the court entered a written order extending the restriction for one year. The Supreme Judicial Court affirmed, holding (1) section 3862-A neither violates Me. Const. art. I, 16, nor is it unconstitutionally vague; (2) the extension of the weapons restriction was supported by competent evidence; and (3) the prosecutor did not commit misconduct during closing arguments. View "In re Weapons Restriction of J." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered after a jury trial, holding that Defendant was not entitled to relief on her allegations of error.After a trial, a jury found Defendant guilty of operating under the influence and of having a blood-alcohol level of .15 grams or more per 210 liters of breath at the time of the offense. The Supreme Judicial Court affirmed, holding that the trial court (1) did not err in denying Defendant's challenge for cause to a prospective juror based on implied bias; and (2) did not violate Defendant's constitutional rights by factoring into her sentence the court's view that her testimony was untruthful without making perjury findings. View "State v. Hemminger" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part the summary judgment entered by the superior court in favor of the City of Lewiston on the City's land use complaint alleging two violations of City ordinances, holding that the court did not have the discretion to allow William Verrinder to pay less than the minimum statutory penalty for each violation.On appeal, Verrinder argued that the superior court erred in concluding that his challenge to the City's notice of violation was barred by the doctrine of administrative res judicata and that the financial penalties imposed for the violations were unconstitutionally excessive. The Supreme Judicial Court vacated in part, holding (1) the superior court correctly determine that the City was entitled to judgment as a matter of law; but (2) the court erred in making the civil penalties it imposed for the two separate violations concurrent with each other rather than cumulative. View "City of Lewiston v. Verrinder" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for certain domestic violence incidents, including possession of a firearm by a prohibited person, holding that Defendant was not entitled to relief on his allegations of error.After a jury convicted him of six offenses Defendant appealed, raising several allegations of error. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant's request for sanctions for the State’s alleged discovery violations; (2) the trial court did not commit obvious error by admitting testimony of a police officer, including certain statements under Me. R. Evid. 801(d)(1)(B); (3) the trial court did not abuse its discretion in admitting an unauthenticated letter that Defendant claimed was written on behalf of the victim; (4) the court did not err when it denied Defendant's motion to dismiss because of the makeup of the jury venire; and (5) there was sufficient evidence for the jury to have rationally found that every element of each count Defendant was convicted of was proved beyond a reasonable doubt. View "State v. Thomas" on Justia Law