Justia Criminal Law Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murdering a deputy sheriff and sentencing Defendant to life imprisonment, holding that there was no error.After his conviction, Defendant filed a motion for a new trial on the ground of newly discovered evidence. In the motion, Defendant asserted that a newly discovered disciplinary report concerning a member of the law enforcement team that arrested him could have been used as impeachment evidence at his trial. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) Defendant failed to show the disciplinary report to him was favorable to him in the first instance; and (2) therefore, Defendant failed to show a reasonable probability that the report would have produced a different verdict at trial if it had been admitted into evidence. View "State v. Williams" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court suppressing Defendant's blood test results in the State's prosecution of Defendant for operating under the influence, holding that the findings of the court did not support its legal conclusion that Defendant did not voluntarily give his consent.In suppressing the blood test results the trial court concluded that the blood draw was a result of simple acquiescence to the trooper's authority. On appeal, the State argued that the trial court erred in concluding that Defendant did not voluntarily consent to the blood draw. The Supreme Judicial Court agreed and reversed the the trial court's order suppressing the evidence, holding that, in the totality of the circumstances, holding that Defendant's response to the trooper's request objectively manifested free and voluntary consent. View "State v. Croteau" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights as to his child, holding that Father was not denied due process and that Father failed to prove his claim of ineffective assistance of counsel.After a hearing, the district court entered an order terminating the parental rights of Mother and Father to their child finding that the parents were unwilling or unable to protect the child from jeopardy or to take responsibility for the child in a time reasonably calculated to meet the child's needs and that termination was in the child's best interest. The Supreme Judicial Court affirmed, holding (1) the trial court's decision to accept a proposed order and findings only from the Department of Health and Human Services did not affect the outcome of the case; and (2) Father was not entitled to relief on his ineffective assistance of counsel claim. View "In re Child of Kenneth S." on Justia Law

The Supreme Judicial Court dismissed as interlocutory this appeal from a partial summary judgment entered by the superior court in favor of Defendants on Plaintiffs' complaint, holding that the court improvidently granted Defendants' motion to certify the partial summary judgment as a final judgment pursuant to Me. R. Civ. P. 54(b)(1).In their complaint, Plaintiffs alleged that Defendants violated common restrictions in the parties' deeds. The superior court granted Defendants' motion for partial summary judgment on count one of Plaintiffs' complaint, but Plaintiffs' remaining claim and Defendants' counterclaims remained pending. Plaintiffs appealed. The Supreme Judicial Court dismissed the appeal, holding that the court's certification of a partial final judgment was based on the flawed premise that the partial summary judgment entered in favor of Defendants could produce a full and final resolution of count one of Plaintiffs' complaint. View "Stiff v. Jones" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for gross sexual assault and sexual misconduct with a child under twelve years of age, holding that the trial court did not err or abuse its discretion in denying Defendant's motion to dismiss the indictment based on an alleged violation of the Interstate Compact on Detainers, Me. Rev. Stat. 34-A, 9601-9636.Defendant pleaded guilty in federal court in New York to possession of child pornography. Thereafter, the state of Maine lodged a detainer against Defendant seeking to have him brought to trial on charges against him for gross sexual assault and sexual misconduct with a child under twelve years of age. Defendant was delivered to Maine and arraigned. In light of restrictions brought on by the COVID-19 pandemic, the State filed a motion to extend the time to bring Defendant to trial for "good cause" under Me. Rev. Stat. 34-A 9603. Defendant objected and moved to dismiss the charges. The trial court granted the State's motion and denied Defendant's motion. The Supreme Court affirmed, holding that the State met its burden of showing that good cause existed for an extension of time. View "State v. Shepard" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder, holding that there was no error.On appeal, Defendant argued that the trial court erred in denying his motion to dismiss the indictment for failure to comply with the Interstate Compact on Detainers and violated his constitutional rights by holding bench conferences in the hallway and by denying his motion to represent himself. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to dismiss based on the Compact; (2) Defendant failed to show obvious error on his argument that holding bench conferences in the hallway violated his public trial rights; and (3) the trial court did not err or abuse its discretion when it denied Defendant's mid-trial request to represent himself. View "State v. Reeves" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction in violation of condition of release entered in the trial court following a jury trial, holding that there was no error.Specifically, the Supreme Judicial Court held (1) the trial court committed no error that affected Defendant's substantial rights in informing the jury of a joint stipulation of facts when the stipulation was signed by Defendant's counsel but not him personally; (2) the trial court did not err in its instructions to the jury; and (3) the evidence presented at trial was sufficient to supporting the jury's finding beyond a reasonable doubt every element of the crime charged. View "State v. Bilynsky" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder, elevated aggravated assault, and robbery, holding that none of Defendant's arguments on appeal had merit.On appeal, Defendant argued that the trial court erred in refusing to instruct the jury on the defense of duress and that the court abused its discretion by precluding his expert witness from expressing an opinion that it was “more likely than not” that the surviving victim was “confabulating” her memory when recalling what happened during the shootings that resulted in the criminal charges. The Supreme Judicial Court affirmed, holding (1) the trial court properly declined to instruct the jury on the defense of duress; and (2) the court did not abuse its discretion in excluding the expert's statement. View "State v. Murray" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction for intentional or knowing murder entered in the trial court following a jury trial, holding that the trial court erred in denying Defendant's motion to suppress evidence and statements that were obtained in violation of Defendant's constitutional rights.In denying Defendant's motion to suppress, the trial court determined that the searches of Defendant's property were not unreasonable because the emergency aid doctrine supported the searches, that suppression would not be justified even if they were, and that Defendant's statements were made voluntarily. The Supreme Judicial Court vacated the judgment of conviction, holding that Defendant's rights under the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution and Me. Const. art. I, 6, 6-A were violated, and that the trial court erred in denying Defendant's motion to suppress. View "State v. Akers" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court accepting Defendant's conditional guilty plea to escape, holding that, by separately trying Defendant for criminal threatening in Sagadahoc County and then for escape in Kennebec County, the State violated Me. Rev. Stat. 17-A, 14.Defendant was arrested for criminal threatening with a dangerous weapon shortly after he allegedly left the custody of a psychiatric center without permission. A jury acquitted Defendant of the criminal threatening charge in Sagadahoc County. Thereafter, the State charged Defendant with escape in Kennebec County. Defendant entered a conditional guilty plea to the charge and then appealed. The Supreme Judicial Court vacated the trial court's judgment, holding (1) Sagadahoc County was a proper venue to prosecute Defendant for escape because it was the county in which he was apprehended; and (2) the trial court's finding that Defendant's alleged threat against a family member arose from the same criminal episode was supported by the record. View "State v. Gessner" on Justia Law