Justia Criminal Law Opinion Summaries

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

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