Justia Civil Rights Opinion Summaries

The two defendants in this case - James Simmons and Frederick Campbell - were each charged with and indicted for two counts of arson. Simmons filed a motion to suppress the evidence seized as a result of search warrants, arguing that the search warrants were not supported by probable cause. The superior court granted the motion and suppressed evidence of cellular telephone records seized pursuant to the warrants. The Supreme Judicial Court vacated in part and affirmed in part, holding (1) the affidavits established probable cause for the State to seize those portions of Simmons’s cell phone records relating to historical cell site location data for a certain day; and (2) the remaining aspects of the suppression order as to Simmons and the order in its entirety as to Campbell were without error. View "State v. Simmons" on Justia Law

After a jury trial, Defendant was convicted of three counts of murder. Defendant filed a motion for a new trial, arguing that he had been deprived of due process by being tried jointly with his co-defendant and by statements made by his co-defendant’s counsel. Specifically, he argued that his co-defendant’s counsel had impermissibly commented upon Defendant’s decision not to testify and his race. After a hearing, the trial court denied the motion for a new trial. The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion for a new trial, holding (1) the court did not abuse its discretion by denying Defendant’s motion to sever his trial from his co-defendant’s; (2) the trial court did not abuse its discretion when it denied Defendant’s motion for a new trial as to the silence-related comments; and (3) the trial court properly determined that three race-related comments were improper but that the comments had not affected Defendant’s substantial rights. View "State v. Daluz" on Justia Law

Defendant entered a conditional plea of nolo contendere to the crime of operating after suspension. A judgment of conviction was entered accordingly. Defendant appealed, arguing that the lower court erred in denying his motion to suppress because the law enforcement officer’s decision to stop his vehicle was pretextual and the stop was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding that the record supported the court’s inferred finding that the stop was supported by a reasonable articulable suspicion of a threat to public safety, and therefore, the lower court did not err in denying Defendant’s motion to suppress. View "State v. Sasso" on Justia Law

Defendant entered a conditional plea to the charge of operating under the influence with two prior convictions for operating under the influence. Defendant appealed the denial of his motion to suppress the evidence obtained from a stop of his vehicle. The trial court concluded that, by a preponderance of the evidence, the arresting officer had an objectively reasonable belief that Defendant had violated Me. Rev. Stat. 29-A, which prohibits braking or accelerating that is “unnecessarily made so as to cause a harsh and objectionable noise.” The Supreme Judicial Court affirmed, holding that there was no error in the court’s findings of fact or conclusions of law. View "State v. Violette" on Justia Law

After a jury trial, Defendant was convicted of criminal threatening. Before trial, Defendant filed a motion to suppress statements he had made after police officers stopped his vehicle, took his license and registration, and asked him to wait for a detective to arrive. The suppression court granted the motion in part but denied it as to the statements Defendant made before he was placed in handcuffs and arrested, holding that Defendant was not in custody until he was placed in handcuffs and that after he was handcuffed he did not waive his Miranda rights. Defendant appealed, arguing that the trial court erred by declining to suppress the statements that he made to the detective before his formal arrest. The Supreme Court vacated the judgment of conviction and vacated the suppression order in part, holding that Defendant was in custody when he responded to the detective’s questions and accusations, and because he was in custody when he made incriminating statements without the benefit of Miranda warnings, those statements were improperly admitted at trial. Remanded. View "State v. King" on Justia Law

In 2014, Defendant entered a conditional guilty plea to operating under the influence (OUI), elevated to a Class C felony by two prior convictions for operating under the influence. Defendant appealed, asserting that his 2013 OUI conviction - one of the two convictions that enhanced his 2014 charge - was obtained in violation of his Sixth Amendment right to counsel, and therefore, the trial court erred in denying his motion to strike that conviction from the indictment. The Supreme Judicial Court affirmed, holding that Defendant failed to meet his burden on collateral attack of demonstrating that he did not knowingly and intelligently waive his right to counsel. View "State v. Kennedy" on Justia Law

Defendant entered a conditional guilty plea to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained from the stop of his vehicle by a game warden. The suppression court found that the warden stopped Defendant’s vehicle after making an “unnecessarily wide” right turn into the approaching lane of another road. The Supreme Court affirmed, holding that the warden’s testimony was sufficient to support the suppression court’s finding that the warden had a reasonable articulable suspicion that Defendant had committed a traffic violation and that the warden’s subjective suspicion was objectively reasonable under the circumstances. View "State v. Simmons" on Justia Law

After a jury trial, Defendant was convicted of two counts of criminal restraint by a parent. Defendant appealed, asserting that the trial court erred by failing to declare a mistrial sua sponte after Defendant’s mother testified that she had visited Defendant in jail. Specifically, Defendant argued that the testimony undermined the fairness of the fact finding process by creating an impression in the jurors’ minds of Defendant’s guilt. The Supreme Court affirmed the conviction, holding that Defendant’s mother’s brief statement at trial likely did not have any effect, much less a prejudicial effect, on Defendant’s right to a fair trial. View "State v. Retamozzo" on Justia Law

After a jury trial, Defendant was convicted of robbery. Defendant proceeded to trial without representation after the trial court determined that Defendant had forfeited his right to counsel after threatening to cause serious bodily harm to one of his attorneys in the presence of another attorney, by his deliberate unwillingness to work with those attorneys’ predecessors, and by failing to show that he would work cooperatively with successor counsel. The Supreme Judicial Court affirmed the trial court’s decision to require Defendant to proceed to trial without legal representation, holding (1) in circumstances of egregious misconduct, an accused can forfeit his right to counsel, and in this case, the trial court did not err in concluding that Defendant’s conduct rose to the level that constituted a forfeiture; and (2) in the alternative, the record established that through his egregious misconduct, Defendant waived his right to counsel by implication. View "State v. Nisbet" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence and violating a condition of release. Defendant was sentenced to a term of sevens days in county jail. On appeal, Defendant argued that the trial court erred in denying his motion to suppress and, at trial, in admitting evidence of his blood-alcohol level derived from a sample of his blood that was seized without a search warrant. The Supreme Judicial Court affirmed, holding that the trial court did not err in denying the motion to suppress, as there were exigent circumstances at the time of the blood draw negating the requirement for a search warrant. View "State v. Arndt" on Justia Law