Justia Civil Rights Opinion Summaries

Defendant was indicted for aggravated trafficking of scheduled drugs, unlawful trafficking in scheduled drugs, and illegal importation of scheduled drugs. Defendant moved to suppress incriminating statements he made to a Maine Drug Enforcement Agency (MDEA) agent while in the agent's custody and after Defendant had invoked his right to counsel in violation of the Fifth Amendment. The superior court granted Defendant's motion after applying Maryland v. Shatzer, concluding that the State had failed to prove that Defendant's waiver of his right to counsel was voluntary because the agent had resumed his questioning of Defendant just a few hours after Defendant had invoked his right to counsel, far less than the fourteen-day standard required by Shatzer. The Supreme Court vacated the superior court, holding that the court erred by evaluating the evidence and rendering its findings through the lens of the Shatzer fourteen-day standard and should have employed the analytical framework advanced in Edwards v. Arizona and Oregon v. Bradshaw in determining whether Defendant voluntarily reinitiated interrogation. Remanded for the court to reconsider the evidentiary record and to apply the Edwards and Bradshaw standards.

Following a jury trial, Rory Holland was convicted of two counts of intentional or knowing murder and sentenced to two concurrent life sentences. The Supreme Court affirmed the judgment and sentences, holding (1) the trial court did not abuse its discretion when it refused to admit evidence of the victims' reputations for violence that was not known to Holland prior to the murders; (2) the trial court did not err in admitting a book containing the Maine Criminal Code into evidence where the evidence was not unfairly prejudicial; (3) the trial court properly denied Holland's motion in limine to permit statements from an earlier civil trial to be admitted into evidence to provide context for Holland's reaction to threats and violence; (4) there was sufficient evidence to disprove Holland's claim of self-defense; (5) the trial court did not err by allowing the State to reopen its case to present evidence regarding identification of Holland; and (6) the court did not abuse its discretion in imposing concurrent life sentences.

While Shawn Sayer was incarcerated, the district court granted a final order for protection from abuse to Liv Morrison. Sayer appealed, asserting, inter alia, that he was deprived of due process by not being given the opportunity to be present at or participate in the hearing. The Supreme Court vacated the judgment of the district court, holding that Sayer's incarceration and the need to protect his rights by facilitating his participation in the hearing, either in person or by a remote video or audio connection, demonstrated good cause to either make an accommodation to allow him to participate in the hearing or grant a short continuance of the hearing to allow his participation on another date. Remanded.

After a jury trial, Daniel Fortune was found guilty on eleven counts related to the attempted murder of a five-member family in their home. The Supreme Court affirmed the convictions and resulting sentences, holding (1) the trial court did not err when it instructed the jury that it could find Fortune guilty of attempted murder if the jury found that the State had proved attempted murder as to one of three victims named in a single count of the indictment; (2) the evidence was sufficient to support Fortune's convictions of the aggravated attempted murders of two of the victims; (3) the aggravated murder statute does not violate the state or federal Constitution; (4) the sentencing court did not err in its application of the sentencing analysis, resulting in the imposition of concurrent life sentences for two counts of aggravated attempted murder, and the court did not err concluding that a split sentence was not available to Fortune; and (5) the fact that the sentencing court did not clearly articulate on the record the three-step sentencing analysis in determining the concurrent sentences imposed on the remaining nine felony counts was harmless, assuming it was error at all.

After a jury trial, Defendant David Churchill was found guilty of one count of unlawful sexual contact. Defendant appealed, arguing that the trial court erred by admitting in evidence a printout of an online chat between Defendant and the victim, a twelve-year-old girl, because the printout was not authenticated pursuant to Me. R. Evid. 901(a). The Supreme Court affirmed, holding (1) the trial court properly concluded that testimony of a police detective was sufficient to authenticate the chat log, and (2) other evidence established that Defendant was the person with whom the victim was chatting, so no greater showing was required.

Defendant was convicted for aggravated trafficking in scheduled drugs. The superior court denied Defendant's motion for a new trial. Defendant appealed, arguing that he was entitled to a new trial because he was denied effective assistance of counsel when his attorney failed to advise him of the immigration consequences of his guilty plea. The Supreme Court affirmed, holding (1) the trial court properly denied Defendant's motion for a new trial because post-conviction review was the exclusive avenue for judicial review of an ineffective assistance of counsel claim; and (2) because Defendant did not avail himself of the post-conviction review process, the Court could not decide if, in light of the Supreme Court's decision in Padilla v. Kentucky, the post-conviction review procedure was unconstitutional as applied to Defendant's circumstances.

Employee brought an employment discrimination claim against Employer pursuant to the Maine Human Rights Act, alleging that Employer discriminated against him based on his sexual orientation. A jury entered a verdict for Employee and awarded Employee compensatory and punitive damages. Employer appealed, arguing, among other things, that it was entitled to judgment as a matter of law on liability. The Supreme Court affirmed, holding (1) the record contained sufficient evidence to support the jury's finding that actions of Employer made it futile for Employee to apply for a promotion, and thus, Employee's failure to apply for the position fell under the futility exception to the rule that an individual must apply for a position before he can claim he was denied that position; (2) the court applied the proper statutory cap to the jury's award; and (3) the trial court did not abuse its discretion in denying Employer's motion for a new trial or remittitur of damages.

After a jury trial, Appellant Scott Brockelbank was convicted of aggravated criminal trespass and assault. The Court of Appeals affirmed Appellant's judgment and sentence, holding (1) the evidence was sufficient to disprove Appellant's competing harms defense because there was sufficient evidence for the jury to find that the State disproved at least one of the elements of the defense; and (2) the sentencing court acted within its discretion by permitting the State to introduce information related to Appellant's nonpublic juvenile adjudication during the sentencing proceedings to the limited extent reasonably necessary to respond to and explain information introduced by Appellant related to the same adjudication.

After a jury trial, Luis Pabon was convicted of elevated aggravated assault and attempted murder for the stabbing of his girlfriend and housemate at the time. Pabon's defense was partially built around the claim that he was so intoxicated that he had stabbed the victim in self-defense. On appeal, Pabon contended that the trial court erred by failing to include a dwelling-place exception to the duty to retreat in its self-defense instruction to the jury. The Supreme Court affirmed the judgment of conviction, holding that the court's omission of the dwelling-place exception from its self-defense instruction was not obvious error.

Defendant Ryan Preston was found guilty of criminal threatening with a dangerous weapon. On appeal, Preston argued (1) that the statutory provisions defining deadly force and discussing defense of premises were unconstitutionally vague, and (2) the trial court did not adequately instruct the jury on the charge of criminal threatening with a dangerous weapon. The Supreme Court affirmed the judgment of the trial court, holding (1) the definition of deadly force was not unconstitutionally vague as it interacted with the definition of defense of premises in this case, and (2) the trial court's jury instructions did not constitute obvious error.