Justia Civil Rights Opinion Summaries

Defendant and two co-conspirators pleaded no contest or guilty to various charges. Defendant pleaded guilty to two counts of intentional or knowing murder. The sentencing court sentenced Defendant to two concurrent terms of forty-five years in prison. Defendant appealed, arguing that the court abused its discretion in sentencing him to a longer prison term than that of his two co-conspirators. The Supreme Court affirmed the sentences, holding that, given the court's consideration of the purposes of sentencing, proper completion of the two-step sentencing procedure for murder, articulation of the reasons for the sentence, and explicit discussion of and adjustment for the sentencing inequality at issue, the sentencing court did not abuse its discretion in sentencing Defendant. View "State v. Hamel" on Justia Law

After the State brought a criminal proceeding against Mark Strong, the court initiated jury selection through a process that had the practical effect of excluding the public, including the media, from voir dire. After Maine Today Media, Inc.'s request that the court open the voir dire process to the public was denied, Maine Today filed a motion to intervene, which the trial court denied. Maine Today filed an interlocutory appeal. The Supreme Court (1) vacated the denial of the motion to intervene and allowed intervention for the limited purpose of the matters addressed in this appeal; and (2) vacated the court's order barring the public from the entirety of the voir dire process. Remanded to the trial court to conduct the remaining voir dire in a presumptively public manner. View "State v. Strong" on Justia Law

After a jury trial, Defendant was found guilty of intentional or knowing murder for killing a sixteen-year-old girl, who was found buried with her wrists bound in duct tape, behind Defendant's mother's home. Defendant was sentenced to forty-seven years' incarceration. The Supreme Court affirmed. Defendant subsequently moved for additional DNA analysis and a new trial, claiming that a trace amount of male DNA previously found in a clipping from the duct tape had been further analyzed, and that Defendant was excluded as the source of that DNA. The post-conviction court denied Defendant's motion for a new trial, holding that the newly discovered DNA evidence did not make a different verdict probable due to the strong evidence of Defendant's guilt and the limited nature of the additional DNA test results. The Supreme Court affirmed, holding that the court did not err in its findings of fact, misapply the relevant statute, or abuse its discretion in denying the motion for a new trial. View "State v. Reese" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and criminal mischief. The Supreme Court affirmed, holding that the jury rationally could have found every element of the offenses beyond a reasonable doubt, as (1) the evidence presented was sufficient to support the jury's findings that Defendant obtained and intended to deprive the State of possession of property with a value greater than $1,000; and (2) the evidence was sufficient to support the jury's findings that Defendant intentionally, knowingly, or recklessly damaged or destroyed property of the State without reasonable grounds to do so. View "State v. Reed" on Justia Law

After a jury trial, Defendant was convicted for the intentional or knowing murder of his roommate. Defendant appealed, arguing that the trial court erred in concluding that he waived his Fifth Amendment privilege against self-incrimination and ordering him to answer a question posed by the State on cross-examination. The Supreme Court affirmed the conviction, holding that the trial court did not abuse its discretion (1) in determining that Defendant waived his Fifth Amendment privilege and in reasoning that the disputed question posed by the State was within the scope of his testimony on direct examination; and (2) in instructing the jurors that they could consider Defendant's unprivileged refusal to answer the State's question on cross-examination. View "State v. Butsitsi" on Justia Law

In the late 1990s, Bryan Carrier pled guilty to three counts of vehicular manslaughter and three counts of aggravated operating under the influence. The judgment and commitment notified Defendant that his license was suspended for life on the manslaughter counts. In 2011, Carrier petitioned for reinstatement of his license. After a hearing, a hearing officer of the Secretary of State's Bureau of Motor Vehicles denied Carrier's petition based on the opposition of the victims' families. The superior court denied Carrier's petition for judicial review. The Supreme Court affirmed, holding that the reinstatement statute allows for consideration of the opinions of the victims and their families. View "Carrier v. Sec'y of State" on Justia Law

When Restaurant was denied a requested liquor license by the Town of Bingham, Restaurant appealed to the Department of Public Safety. After a hearing, a Department hearing officer also denied the license. On appeal, Restaurant asserted various independent claims alleging constitutional and statutory violations by the Department and Town. The appellate court found in favor of Defendants on Restaurant's independent claims but, on the merits, remanded the matter to the Department after concluding that an appeal of a municipality's denial of a liquor license could only be decided by the Commissioner of Public Safety and not a hearing officer. On remand, the Commissioner of the Department denied the license application. The Supreme Court affirmed, holding (1) the deficiencies in the Department's notice to Restaurant of the hearing on Restaurant's requested liquor license constituted harmless error in the circumstances presented by this case; (2) The Department had sufficient grounds on which to deny Restaurant's liquor license; and (3) the court did not err in entering a judgment against Restaurant on its 42 U.S.C.S. 1983 claims. View "Antler's Inn & Rest., LLC v. Dep't of Pub. Safety" on Justia Law

After a jury trial, Defendant was convicted of intentional and knowing murder. The trial court sentenced Defendant to thirty-five years in prison. Defendant appealed, arguing (1) the court erred in denying him a new trial based on the State's failure to produce exculpatory evidence, (2) the court violated the equal protection right of a juror removed from the panel given his inability to deliberate past 5:08 p.m. for religious reasons, and (3) there was insufficient evidence to support his conviction. The Supreme Court affirmed the judgment, holding (1) Defendant received a fair trial in this matter; (2) there was no disparate treatment of the juror, and therefore, the juror's equal protection rights were not violated; and (3) there was no error in the trial court's entry of the judgment of conviction or its sentencing analysis. View "State v. Carr" on Justia Law

Employee filed this action against Employer and her four individual supervisors (Supervisors), claiming whistleblower discrimination pursuant to the Whistleblowers' Protection Act (WPA) and the Maine Human Rights Act (MHRA) and sex discrimination pursuant to the MHRA. The superior court granted Supervisors' motion to dismiss, finding they could not be held individually liable pursuant to the WPA and the MHRA. The court then entered summary judgment in favor of Employer on all claims. Employee appealed, contending (1) summary judgment for Employer was improper because she presented a prima facie case of whistleblower discrimination and there remained material facts in dispute, and (2) the dismissal of her claims against Supervisors was improper. The Supreme Court affirmed with respect to the sex discrimination claim and the dismissal of Supervisors but vacated the judgment with respect to the whistleblower discrimination claim against Employer, holding (1) material facts remained in dispute regarding Employee's whistleblower claim; but (2) the WPA and MHRA do not provide for individual supervisor liability. View "Fuhrmann v. Staples the Office Superstore E., Inc." on Justia Law

Following a nonjury trial, Defendant was convicted of domestic violence assault. Defendant's sentence included a period of two years of probation with a requirement that he participate in a certified batterers' intervention program. Defendant contended that his sentence violated the Equal Protection clauses of the U.S. and Maine Constitutions because, he asserted, a woman convicted of the same crime could not be sentenced to a term of probation of more than one year. The Supreme Court vacated the sentence and remanded for additional proceedings because there was no factual record from which the Court could evaluate Defendant's and the State's arguments. View "State v. Mosher" on Justia Law