Justia Civil Rights Opinion Summaries

Berwick Iron & Metal Recycling, Inc. operated a metal and automobile recycling business under an existing conditional use permit. In 2010, Berwick Iron applied for a conditional use permit to install and operate a metal shredder. On remand, the Berwick Planning Board voted to approve the conditional use permit. The superior court vacated the Board's judgment, concluding that the Board erred in applying the ordinance governing air emissions. Both parties appealed. On cross-appeal, the abutters argued, among other things, that the superior court erred in concluding that the Board did not violate the abutters' due process rights by communicating ex parte with representatives from Berwick Iron. The Supreme Court vacated the superior court's judgment and remanded for entry of a judgment affirming the Board's decision, holding that, despite the Board's ex parte communications with Berwick Iron, the Board did not violate the abutters' due process rights or err in applying its ordinance. View "Duffy v. Town of Berwick" on Justia Law

This case involved three Enhanced 9-1-1 (E-9-1-1) calls regarding an altercation that resulted in three people being shot. MaineToday Media, Inc. sent a series of requests to inspect and copy the three transcripts to the police department, state police, attorney general, and others. The State denied the requests, claiming that the transcripts constituted "intelligence and investigative information" in a pending criminal matter and were therefore confidential under the Criminal History Record Information Act. MaineToday filed suit against the State, arguing that the Freedom of Access Act (FOAA) mandated disclosure of the transcripts as public records and that no exception to their disclosure applied. The superior court affirmed the State's denial of MaineToday's request. The Supreme Court vacated the lower court's judgment, holding that the E-9-1-1 transcripts, as redacted pursuant to 25 Me. Rev. Stat. 2929(2)-(3), were public records subject to disclosure under the FOAA. View "MaineToday Media, Inc. v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault, criminal threatening with a dangerous weapon, criminal restraint, and violation of a condition of release. The Supreme Court affirmed, holding (1) the trial court did not err in admitting evidence related to the events that preceded Defendant's arrest; (2) the trial court did not err in admitting testimony regarding the methods the police used to compile a photographic array that was shown to the victim; and (3) the prosecutor did not commit misconduct by improperly vouching for the victim's credibility during closing argument because, viewed in context, the prosecutor's statement was not witness-vouching or otherwise improper. View "State v. Hassan" on Justia Law

After a jury trial, Defendant was convicted of aggravated attempted murder, aggravated criminal mischief, reckless conduct with a dangerous weapon, eluding an officer, and theft by unauthorized taking or transfer. Defendant appealed, arguing (1) the trial court erred when it failed, sua sponte, to instruct the jury on self-defense and voluntary intoxication, and (2) the trial court erred when it did not conduct a colloquy directly with him to confirm he knowingly and voluntarily chose not to testify. The Supreme Court affirmed, holding (1) Defendant waived jury instructions on self-defense and intoxication, and therefore, the trial court did not commit obvious error by not instructing on those defenses; and (2) Defendant waived his right to testify, and therefore, the trial court committed no error here by confirming the election not to testify through counsel. View "State v. Ford" on Justia Law

Defendant, who was eighteen years old at the time, was badly injured in a single-vehicle accident. While she lay sedated at the hospital, a police trooper, without providing Miranda warnings, questioned Defendant about the car accident, seeking information as to who was driving. After a pause in the questioning, the trooper told Defendant that two of her friends who had been in the car were dead and urged Defendant to tell the truth about who was driving. Defendant subsequently made inculpatory statements. Defendant was indicted on two counts of manslaughter, two counts of aggravated criminal OUI, and one count of leaving the scene of an accident that resulted in serious bodily injury. The trial court granted Defendant's motion to suppress as to all statements Defendant made after the pause in the interview, concluding (1) at that point, Defendant became a suspect and was in custody because she reasonably did not believe that she was free to terminate the interview; and (2) consequently, Defendant should have been given Miranda warnings. The Supreme Court affirmed, holding that the district court did not err in finding that Defendant's statements throughout were voluntary but that Defendant was in custody after the break in the interview. View "State v. Lowe" on Justia Law

After a jury-waived trial, Appellant was convicted of aggravated criminal trespass and unlawful sexual contact. Appellant appealed his conviction, contending that, because he was motivated by his subconscious thoughts, was experiencing a blackout, and was under the influence of prescription drugs and alcohol during the encounter with the victim, he was not consciously aware of his acts and therefore did not act with the requisite culpable state of mind when he entered the victim's dwelling without her permission and subjected her to sexual contact without her consent. The Supreme Court affirmed, holding that, in this instance, substantial evidence existed to show that Appellant's actions were taken knowingly and with intent. View "State v. Kepner" on Justia Law

After a jury trial, Defendant was convicted of domestic violence assault. Defendant appealed, arguing that the State's closing argument contained comments that impermissibly drew attention to her decision not to testify in her own defense. The Supreme Court affirmed the judgment of the trial court, holding (1) the prosecutor's statements were accurate recitations of the state of the evidence and did not expressly or implicitly comment on Defendant's failure to testify or suggest that the evidence must be accepted because it was unrebutted; and (2) therefore, the statements did not constitute misconduct. View "State v. Bean" on Justia Law

After a jury trial, Defendant was convicted of three counts of murder and one count of arson. The trial court imposed three concurrent life sentences on the murder convictions and a consecutive fifteen-year sentence on the arson conviction. The Supreme Court affirmed the judgment and the sentences, holding that the trial court did not err in (1) denying Defendant's motion to suppress statements that he made to the police, as the confessions were made voluntarily and their admission at trial did not violate Defendant's Fifth Amendment rights; (2) declining to instruct the jury concerning the potential consequences of a verdict of not criminally responsible by reason of insanity; and (3) sentencing Defendant. View "Maine v. Ormsby" on Justia Law

After a jury trial, Defendant was convicted of theft by misapplication of property and securities fraud. Defendant appealed, contending that the court's jury instructions impermissibly shifted the burden of proof onto him to prove his innocence. The Supreme Court affirmed, holding that the burden of proof was not improperly shifted onto Defendant to prove his innocence where (1) there was no obvious error in the instructions the trial court gave because, as a whole, the instructions correctly stated the law; and (2) the court correctly stated the State's burden of proof and Defendant's presumption of innocence several times during the jury selection, at the beginning of the trial, in its final instructions, and in its written instructions sent to the jury room. View "State v. Philbrook" on Justia Law

After a jury trial, Defendant was convicted of unlawful sexual contact and unlawful sexual touching. This was the third trial held after two mistrials in this case. The Supreme Court affirmed, holding that the trial court did not err in (1) delcaring a mistrial at the second trial; (2) denying Defendant's motion for a new trial filed after the third trial on grounds of prosecutorial misconduct in the prosecutor's gestures during the third trial, which Defendant claimed telegraphed the prosecutor's personal opinion or witness credibility; and (3) failing to limit, on its own initiative, alleged misstatements of law and fact that the prosecutor made in closing argument and in rebuttal at the third trial. View "State v. Carey" on Justia Law