Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the unified criminal docket convicting Defendant of unlawful sexual contact, holding that the trial court did not err when it admitted in evidence as past recollection recorded a video recording in which the victim described Defendant's assaults of her.The video recording was of a forensic interview conducted of the victim shortly after the crime occurred. On appeal, Defendant argued that the court erred in admitting the video in evidence because the State had not established the proper foundation required by the exception to the hearsay rule and because the admission of the video violated his constitutional right to confront the witness. The Supreme Judicial Court disagreed, holding (1) the court did not err by determining that the State had satisfied the foundational elements of the recorded recollection exception to the hearsay rule; and (2) the court did not violate Defendant's constitutional right to confrontation by admitting the evidence because Defendant was provided the opportunity to cross-examine the victim about her out-of-court statements. View "State v. Adams" on Justia Law

The Supreme Judicial Court Defendant's conviction of multiple sex crimes, holding that the trial court did not err in the jury selection process when it denied Defendant's motion to strike one of the jurors for cause and when it denied Defendant's motion to strike the entire venire after one prospective juror left the courtroom in an agitated state.At the beginning of jury selection, one prospective juror abruptly left the room when the charges against Defendant were being described. The court asked the remaining pool of jurors if there was anyone who would have difficulty being fair and impartial going forward, and thirty-four potential jurors answered in the affirmative. Defendant filed a motion to strike the entire jury venire. The court denied the motion, instead striking the thirty-four potential jurors. Defendant later moved to strike one juror on the ground that he had been equivocal about his ability to remain fair and impartial. The Supreme Judicial Court denied the motion. The Supreme Judicial Court affirmed, holding that the circumstances of this case did not present an extraordinary situation in which prejudice may be presumed or bias implied and that the court did not err in determining that the individual juror's ability to be fair and impartial was not affected. View "State v. Carey" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of murder but finding him guilty of felony murder and robbery in connection with a drug-related homicide, holding that Defendant's conviction for both felony murder and the underlying felony of robbery violated the constitutional protection from double jeopardy.Specifically, the Court held (1) the trial court did not err, while exercising its gatekeeping function, by declining to admit certain hearsay statements because the admission of those statements would have run contrary to the truth-seeking function of Me. R. Evid. 804(b)(3); and (2) although Defendant did not raise the double jeopardy issue in the trial court, the State acknowledged that Defendant's convictions for both robbery and felony murder violated the double jeopardy clauses of the state and federal constitutions, and therefore, the case must be remanded for further post-trial proceedings to eliminate the double jeopardy effect arising from the two charges. View "State v. Armstrong" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for murder, holding that that trial court erred by excluding evidence of Defendant's guilty plea to the murder charge but that the error was harmless.Specifically, the Supreme Judicial Court held (1) the court erred by excluding certain evidence purporting to show that Defendant's friend was responsible for the murder, including evidence that Defendant's friend had pleaded guilty to murdering the same victim, but the error was harmless because of the magnitude and strength of the State's evidence; and (2) the sentence of sixty-five years in prison was constitutional and did not violate either the Eighth Amendment to the United States Constitution or Me. Const. art. I, 9, and the sentence was proportionate, even for someone who, like Defendant, was eighteen years old when he was arrested. View "State v. Dobbins" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for manslaughter entered after a jury trial, holding that any error in admitting certain testimony and in challenged remarks made by the prosecutor during closing argument did not require reversal of the conviction.Specifically, the Court held (1) Defendant failed to preserve for review her objection to the admission of certain testimony, and a challenged statement by another witness was not unfairly prejudicial; (2) certain misstatements made by the State during its closing argument did not rise to the level of prosecutorial misconduct; (3) the evidence was sufficient to support the conviction; (4) the trial court did not abuse its discretion in denying Defendant's motion for voir dire and a new trial based on allegations of juror misconduct; and (5) Defendant's sentence is constitutional. View "State v. Scott" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for burglary, stealing drugs, and violation of a condition of release, holding that the trial court did not err when it denied Defendant's motion to suppress al evidence obtained as a result of the State's acquisition of Defendant's cell phone's location information (CSLI).Specifically, the Supreme Court held (1) because Defendant lacked standing to challenge evidence obtained as a result of the acquisition of a coperpetrator's CLSI, which was the same evidence Defendant sought to exclude based on the acquisition of his own CSLI, this Court need not decide whether the acquisition of Defendant's CSLI was a search under the Fourth Amendment; (2) whether the State violated Defendant's rights under Maine's Electronic Device Location information Act, 16 Me. Rev. Stat. 647 to 650-B, was irrelevant to whether the court erred in denying Defendant's motion to suppress; and (3) the entry into and search of Defendant's residence were lawful. View "State v. O'Donnell" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Mother and Father to their child, holding that there was no error in the proceedings below.On appeal, Mother argued that the district court erred in denying her motion for relief from the termination judgment, in which she alleged that she received ineffective assistance of counsel. Father argued that there was insufficient evidence to support the termination of his parental rights. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion by denying Mother's motion for relief from the termination of her parental rights; and (2) there was sufficient evidence in the record to support the court's termination of Father's parental rights. View "In re Child of Dawn B." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of aggravated assault and violating a condition of release, holding that the sanctions imposed on the State were sufficient to remedy the prejudice caused by discovery violations and that there were no other errors in the proceedings below.Specifically, the Court held (1) the court did not abuse its discretion to impose sanctions for the State's discovery violations; and (2) Defendant was not deprived of his Sixth Amendment right to an impartial jury that represented a fair cross section of Defendant's community, and accordingly, the trial court did not err in denying Defendant's motion for a new jury. View "State v. Townes" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review asserting that he had received ineffective assistance of counsel at a probation revocation hearing, holding that the trial court did not err but, as recently announced in Petgrave v. State, __ A.3d ___ (2019), Defendant now has a procedure by which he can pursue his claim.In Petgrave, the Supreme Judicial Court held that a defendant has a right to the effective assistance of counsel at a revocation hearing and that a defendant who contends that he or she received ineffective assistance of counsel at a probation revocation hearing may pursue that claim by filing a properly supported motion for a new trial pursuant to M.R.U. Crim. P. 33. In the instant case, the Court held that Appellant may file a motion for a new revocation hearing in the trial court within thirty-five days following the issuance of the Court's mandate. View "Gould v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review alleging ineffective assistance of counsel in his probation revocation matter but that Appellant may file a motion for a new probation revocation hearing in the trial court within thirty-five days of the issuance of this mandate.The trial court concluded that Appellant's remedy for any claim of error arising from the revocation was to seek a discretionary appeal, as Appellant had already done. The Supreme Judicial Court held (1) in a probation revocation hearing, a defendant has a right to the effective assistance of counsel; (2) Appellant's motion was properly dismissed, but Appellant was deprived of an opportunity to obtain meaningful review on his claim; and (3) a defendant who seeks to raise a claim of ineffective assistance of counsel after a probation revocation hearing may do so by filing a motion under Rule 33 of the Maine Rules of Unified Criminal Procedure for a new trial, which must be filed thirty-five days after the entry of judgment, and the judge who issued the revocation judgment will, if the defendant has made out a prima facie claim of ineffective assistance, will hold an evidentiary hearing or dismiss the motion. View "Petgrave v. State" on Justia Law