Articles Posted in Maine Supreme Judicial Court

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The district court granted Defendant’s motion to suppress evidence that resulted in a criminal complaint charging Defendant with operating under the influence, concluding that a police officer violated the Fourth Amendment when he ordered Defendant to leave his house in order to complete a traffic stop due to defective license plate lights. The district court concluded (1) the officer did not have probable cause to suspect any criminal activity, and no exigent circumstances existed when he ordered Defendant to exit his house; and (2) the officer’s verbal order to come outside amounted to an unlawful seizure of Defendant. The Supreme Judicial Court vacated the order of suppression, holding (1) the police officer had probable cause to arrest Defendant for the crime of failure to stop his vehicle on request or signal of a uniformed law enforcement officer and pursued him immediately and continuously from the scene of the crime into the curtilage of his home; and (2) therefore, the seizure of Defendant did not amount to unlawful seizure or arrest. View "State v. Blier" on Justia Law

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The Supreme Judicial Court vacated an order entered by the trial court suppressing evidence seized from Defendant, his vehicle, and his residence after the court concluded that the warrant authorizing the search and seizure of the evidence was not supported by probable cause. On appeal, the State argued that the information presented in the warrant affidavit was sufficient for the warrant judge to find that there was probable cause that evidence of a crime would be found in Defendant’s car, in his home, and on his person. The Supreme Judicial Court agreed, holding that the warrant affidavit provided the necessary substantial basis for the warrant judge’s finding of probable cause. View "State v. Mariner" on Justia Law

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After Henry B. was admitted to Pen Bay Medical Center (PBMC), PBMC staff applied to involuntarily commit Henry pursuant to the “white paper” procedures of Me. Rev. Stat. 34-B, 3863(5-A). After a commitment hearing, the district court ordered that Henry be submit to involuntary hospitalization for up to 120 days. The superior court affirmed the district court’s judgment of involuntary commitment. Henry appealed, arguing that he was not provided with effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) individuals subject to involuntary commitment proceedings in Maine have the right to effective representation of counsel, and the Strickland standard applies for courts reviewing claims of ineffective assistance of counsel in involuntary commitment proceedings; and (2) Henry was not deprived of the effective assistance of counsel in this case. View "In re Henry B." on Justia Law

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After a jury trial, Defendant was convicted of fourteen criminal offenses, including four counts of aggravated attempted murder. The trial court imposed multiple life sentences in addition to multiple lesser sentences, all to be served concurrently. The Supreme Judicial Court affirmed the convictions and sentences. Defendant filed a petition for post-conviction review, asserting several grounds for relief, including ineffective assistance of appellate counsel. The court denied the petition, concluding that no error by appellate counsel was sufficiently prejudicial to justify any relief. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to relief under Strickland v. Washington. View "Fortune v. State" on Justia Law

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After a jury trial, Defendant was convicted of two counts of gross sexual assault, two counts of aggravated assault, and other charges. The Supreme Judicial Court affirmed the judgment, holding that the trial court (1) did not deprive Defendant of a fair trial by denying his motion for sanctions and a continuance based on the State’s late disclosure of the victim’s medical records; (2) did not violate Defendant’s right of confrontation when it admitted a recorded interview of the victim; and (3) did not deprive Defendant of a fair trial by precluding him from calling two late disclosed witnesses not included on the witness list described to the jury. View "State v. Gagne" on Justia Law

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Defendant was charged with operating under the influence. After a trial, the court concluded that the jury was genuinely deadlocked and sua sponte declared a mistrial due to manifest necessity. Defendant then moved to dismiss the criminal complaint against him on double jeopardy grounds and on the grounds that the prosecutor had committed misconduct. The court denied Defendant’s motion to dismiss, concluding that the double jeopardy clauses of the federal and state constitutions did not bar a second prosecution and that there had been no prosecutorial misconduct. The Supreme Judicial Court affirmed, holding (1) there was a manifest necessity for a mistrial due to a genuinely deadlocked jury; and (2) Defendant’s allegations of prosecutorial misconduct were unfounded. View "State v. Jandreau" on Justia Law

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Plaintiffs were employed by Shaw’s Supermarkets, Inc. when their employment was terminated as part of a reduction in force. The reduction in force affected more older employees than younger employees. Plaintiffs filed complaints with the Maine Human Rights Commission alleging age discrimination in violation of the Maine Human Rights Act (MHRA). A Commission investor applied the “business necessity” framework to analyze Plaintiffs’ allegations before recommending that the Commission find reasonable grounds to believe that Shaw’s had impermissibly discriminated based on age pursuant to a disparate impact theory. The Commission voted unanimously to adopt the investigator’s analysis and recommendations. Plaintiffs then filed a complaint alleging unlawful employment discrimination based on age pursuant to the MHRA. The federal district court certified to the Supreme Court the question of what framework of proof applies to a claim of disparate impact age discrimination brought pursuant to the MHRA. The Supreme Court answered that a claim for disparate impact age discrimination pursuant to the MHRA is evaluated according to the “business necessity” standard, rather than the “reasonable factor other than age” standard or some other standard. View "Scamman v. Shaw's Supermarkets, Inc." on Justia Law

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Defendant was charged by complaint with operating under the influence based in part on an allegation of a blood test measuring 0.15 grams of alcohol per 100 milliliters of blood. Defendant moved to suppress the evidence obtained through the blood test. The trial court granted the motion to suppress, finding that the police officer did not obtain a warrant or seek Defendant’s consent, that Defendant did not consent to the blood test, and that there were no exigent circumstances generating an exception to the warrant requirement. The State appealed. The Supreme Judicial Court affirmed, holding that the record did not compel a finding that Defendant objectively manifested consent to the drawing and testing of his blood through his mere acquiescence and cooperation. View "State v. Boyd" on Justia Law

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After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and theft by deception. Defendant appealed, arguing (1) the evidence presented at trial was insufficient to support the convictions, and (2) the trial court violated her right to be free from double jeopardy by convicting and sentencing her on both counts of theft without consolidating them. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support both convictions; and (2) the trial court did not err by entering a judgment of conviction on each count of theft or by sentencing Defendant on both counts of theft, and furthermore, there was no violation of Defendant’s right to be free from double jeopardy because the convictions and sentences were not based on a single criminal act. View "State v. Hayward" on Justia Law

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Defendant pleaded guilty to three counts of gross sexual assault and two counts of unlawful sexual contact. The court sentenced Defendant to twenty years’ imprisonment followed by fifteen years of supervised release. Defendant challenged his sentence on appeal, arguing, inter alia, that the supervised release sentencing process, mandated by law, violates the due process clause and the double jeopardy clause. The Supreme Judicial Court affirmed, holding (1) Defendant’s due process argument actually addresses the length of his total sentence, and the sentence is not constitutionally disproportionate or cruel or unusual punishment; (2) the supervised release sentencing process does not violate the Double Jeopardy Clause; and (3) the supervised release statutory scheme does not abrogate the traditional Hewey analysis. View "State v. Parker" on Justia Law