Justia Civil Rights Opinion Summaries

Articles Posted in Maine Supreme Court
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After a six-day jury trial, Defendant was convicted of gross sexual assault and sentenced to a term of twenty-four years. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit obvious error in denying Defendant’s access to immigration records pertaining to the victim’s mother; (2) the process used by the trial court to ensure that Defendant, who spoke Spanish, received adequate interpretation services at trial was appropriate and was not in error; and (3) the remainder of Defendant’s arguments on appeal were without merit. View "State v. Marroquin-Aldana" on Justia Law

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After a jury trial, Defendant was found guilty of intentional or knowing murder and sentenced to seventy years imprisonment. Defendant appealed, arguing, inter alia, that the trial court violated his right to confront witnesses by admitting medical examiner testimony because the testimony relied in part on an autopsy report created by a different medical examiner who did not testify at trial. The Supreme Court affirmed, holding (1) pursuant to State v. Mitchell, the admission of the medical examiner’s testimony was not a violation of the Confrontation Clause; and (2) Defendant’s remaining assertions of error were unavailing. View "State v. Mercier" on Justia Law

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After a jury trial, Defendant was found guilty of two counts of knowing or intentional murder and sentenced to two concurrent sentences of life imprisonment. The Supreme Court affirmed the judgment and sentence, holding (1) the evidence presented at trial was sufficient for the jury to find all of the elements of the crime charged; (2) the sentencing court did not misapply sentencing principles; and (3) the sentencing court did not abuse its discretion when it determined that aggravating and mitigating factors did not require a departure from the basic sentence, and the court did not impermissibly or unconstitutionally impose a sentence that was more severe based upon Defendant’s exercise of his right to a trial. View "State v. Hayden" on Justia Law

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After a jury trial, Defendant was found guilty of several sex offenses. The Supreme Court affirmed after clarifying the conduct the State was required to prove in order to prove the element of penetration, holding that the trial court did not err in (1) denying Defendant’s motion for a judgment of acquittal on the charge of unlawful sexual conduct, as the jury could have rationally made the finding that the State proved beyond a reasonable doubt every element of the offense; and (2) conducting voir dire, as no individual voir dire member disclosed a general bias against a defendant with mental illness. View "State v. Gladu" on Justia Law

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After a jury trial, Defendant was convicted of criminal operating under the influence and refusing to sign a uniform summons and complaint. On appeal, Defendant argued, among other things, that he did not properly waive his right to be assisted by counsel at trial. The Supreme Court vacated the judgment, holding that the record did not reflect - either through Defendant’s own responses to the court regarding the trial process, counsel’s statements regarding Defendant’s waiver, or evidence regarding whether Defendant was informed about the trial process - that Defendant voluntarily, knowingly, and intelligently waived his constitutional right to counsel. View "State v. Hill" on Justia Law

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After a jury trial, Defendant was found guilty of operating after habitual offender revocation. Defendant appealed, arguing (1) the trial court erred when it failed to clarify the definition of “public way” as defined in Me. Rev. Stat. 17-A, 505(2); (2) the statute’s language is confusing and unconstitutionally vague; and (3) the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) Defendant failed to preserve her clarification argument; (2) the language of the statute is outdated and confusing but describes a certain type of public way with sufficient certainty to survive a due process challenge; and (3) the evidence was sufficient to support the verdict. View "State v. Stanley" on Justia Law

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John and Jane Doe, the parents Susan Doe, a transgender girl, filed a complaint with the Maine Human Rights Commission alleging that Regional School Unit 26 (RSU 26) had violated the Maine Human Rights Act (MHRA) by excluding Susan from the communal girls’ bathroom at elementary and middle school. The Commission found reasonable grounds to believe discrimination had occurred. Thereafter, the Does and the Commission filed a complaint in the superior court asserting claims for unlawful discrimination in education (Count I) and unlawful discrimination in a place of public accommodation (Count II) on the basis of sexual orientation. The superior court granted RSU 26’s motion for summary judgment on all counts. The Supreme Court vacated the judgment of the superior court, holding that where it has been clearly established that a student’s psychological well-being and educational success depend on being permitted to use the communal bathroom consistent with her gender identity, denying the student access to the appropriate bathroom constitutes sexual orientation discrimination in violation of the MHRA. Remanded for entry of summary judgment for the Does and the Commission. View "Doe v. Reg'l Sch. Unit 26" on Justia Law

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Plaintiff was a public assistance recipient who was accepted to rent an apartment owned by RRE Coach Lantern Holdings, LLC. Plaintiff’s caseworker indicated that Coach Lantern would have to include a Housing and Urban Development (HUD) tenancy addendum in Plaintiff’s lease for Plaintiff to be able to use her voucher for subsidized rent. Coach Lantern refused to include the addendum in Plaintiff’s lease. Because Plaintiff could not use the voucher unless Coach Lantern included the addendum in her lease, Plaintiff did not rent the apartment. Plaintiff subsequently filed a complaint with the Maine Human Rights Commission alleging that Coach Lantern’s policy of refusing to include the HUD tenancy addendum in her lease constituted a refusal to participate in the voucher program, which amounted to discrimination against Plaintiff on the basis of her status as a public assistance recipient in violation of the Maine Human Rights Act (MHRA). The superior court entered summary judgment in favor of Coach Lantern. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Coach Lantern because the undisputed facts showed that Coach Lantern did not discriminate against Plaintiff in violation of the MHRA. View "Dussault v. RRE Coach Lantern Holdings, LLC" on Justia Law

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After a jury trial, Defendant was found guilty of two counts of aggravated trafficking of a schedule W drug within one thousand feet of a school and of twice violating the conditions of his release in a related case. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant subsequently filed a petition for post-conviction review, asserting that he received ineffective assistance of counsel by failing to conduct a reasonable investigation to discover three recent pending criminal matters against a key witness and in failing to impeach the credibility of the witness on that basis. The post-conviction court denied relief. The Supreme Court affirmed, holding (1) the record supported the court's finding that defense counsel provided effective assistance regarding the witness' second and third criminal matters; and (2) the court did not err in concluding that discovering and impeaching the witness on the first criminal matter likely would not have affected the outcome of the trial. View "Lamarre v. State" on Justia Law

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Defendant was indicted on charges of burglary and theft. Defendant filed a motion to suppress the evidence obtained pursuant to three search warrants for Defendant's house, garage, and car. The superior court granted the motion to suppress, concluding that the first affidavit did not establish probable cause for a search and that the evidence seized pursuant to the third search warrant, which allowed officers to search Defendant's house again after the initial search, must be suppressed as fruit of the poisonous tree. The Supreme Court affirmed the suppression of the evidence obtained in the three searches, holding (1) the first affidavit provided an insufficient basis for a finding of probable cause; (2) the officers' reliance on the warrants was not objectively reasonable; and (3) because the third warrant relied heavily on observations officers made while executing the first warrant, the evidence seized pursuant to that warrant must also be suppressed. View "State v. Johndro" on Justia Law