Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed in part and vacated in part an order of the trial court suppressing evidence seized pursuant to a warrantless search of Defendant’s jacket and vehicle, holding that the search of Defendant’s jacket was a lawful search incident to arrest but that the search of Defendant’s vehicle was not supported by probable cause and was outside the scope of a vehicle search incident to arrest.The trial court concluded that the searches of Defendant’s jacket and vehicles and the seizure of the evidence was not supported by probable cause and violated Defendant’s Fourth Amendment rights. The State appealed, arguing that the search of Defendant’s jacket was a lawful search incident to her arrest and that the evidence discovered in the jacket supported the subsequent search for the illegal drugs discovered in Defendant’s vehicle. The Supreme Judicial Court agreed with respect to the search of Defendant’s jacket but vacated the suppression order as to the evidence found in the vehicle. View "State v. Pagnani" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for aggravated trafficking of scheduled drugs following his guilty plea, holding that the motion court did not err in denying Defendant’s motion to suppress evidence seized by, and statements made to, police officers after he was arrested without a warrant.On appeal, Defendant argued that the police lacked sufficient probable cause to believe that he was engaged in criminal conduct to justify his warrantless arrest. Therefore, Defendant argued, the statements made and evidence seized after the arrest were subject to suppression. The Supreme Judicial Court disagreed, holding (1) sufficient corroborated information warranted any prudent and cautious person to believe that Defendant was committing the offense of heroin trafficking; and (2) therefore, law enforcement officers properly made the warrantless arrest. View "State v. Journet" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of aggravated operating under the influence and aggravated assault, holding that the court did not err in denying Defendant’s motion to suppress evidence of his alcohol level determined from a sample of Defendant’s blood that was seized without a warrant.Specifically, the Court held (1) probable cause existed for a law enforcement officer to obtain a sample of Defendant’s blood in the context of an operating under the influence investigation, and (2) exigent circumstances justified the warrantless blood draw because Defendant was about to go into surgery where he would not be available for a blood draw as part of the State’s investigation and his body would further metabolize any alcohol that might be in his blood. View "State v. Palmer" on Justia Law

The Supreme Judicial Court held that the trial court did not err in determining that the State did not engage in purposeful discrimination when it used a peremptory challenge that excluded from the jury the sole person of color in the jury pool.The Supreme Judicial Court affirmed the judgment of conviction entered in the Unified Criminal Docket convicting Defendant of reckless conduct with a dangerous weapon and criminal threatening with a dangerous weapon. On appeal, Defendant, who described himself as an African American male, argued that the State engaged in purposeful discrimination when it peremptorily challenged the juror at issue. The Supreme Judicial Court disagreed, holding that the trial court did not err when it determined that the prosecutor did not engage in purposeful discrimination. View "State v. Hollis" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court granting Appellant’s petition for postconviction relief and vacating his conviction of sexual abuse of a minor, holding that the court’s factual findings were supported by competent evidence in the record.After a hearing, the postconviction court found that Appellant had been deprived of the effective assistance of counsel and vacated his conviction. The Supreme Court affirmed, holding that the postconviction court’s finding that Appellant had been deprived of the effective assistance of counsel at trial was supported by competent record evidence. View "Fahnley v. State" on Justia Law

The Supreme Judicial Court affirmed the trial court’s denial of Defendant’s motion to suppress his blood-alcohol test results as having been procured without a warrant and without voluntary consent, holding that Defendant consented to the blood test.The blood test was taken upon probable cause to believe that the ability of Defendant, the driver of the motor vehicle, to operate the vehicle was impaired by intoxicants. On appeal, Defendant argued that the blood test was unconstitutional because it was taken without a warrant and her consent to the test was rendered involuntary by the warning of an increased minimum sentence if she refused to consent and was then convicted. The Supreme Judicial Court disagreed, holding that no coercion results from a law enforcement officer’s statement to a driver that, if she is ultimately convicted of operating under the influence, her failure to submit to a blood draw would subject her to an enhanced criminal penalty, including a minimum mandatory jail term. View "State v. Lemeunier-Fitzgerald" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his child pursuant to Me. Rev. Stat. 22, 4055(1)(A)(1)(a) and (B)(2)(a), (b)(i)-(iv), holding that Father failed to present a prima facie case of ineffective assistance of counsel and that the record evidence supported the court’s findings and discretionary determinations.On appeal, Father argued that his counsel’s withdrawal two months before the termination hearing amounted to ineffective assistance of counsel. The Supreme Judicial Court disagreed, holding that Father did not demonstrate prejudice from counsel’s performance. View "In re Child of Stephen E." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of assault, holding that Defendant was not denied a fair trial because one of the jurors reported that she had felt pressured to return a guilty verdict.After the court informed the parties of the juror’s statement and invited the parties to be heard, the court concluded that there was no evidence of juror misconduct and that the guilty verdict would stand. The Supreme Judicial Court held that Defendant was not deprived of a fair trial because there was no evidence of outside influence, bias, or misconduct, and therefore, the juror’s statement that she felt pressured to return a guilty verdict fell within the categories of evidence prohibited from use by Me. R. Evid. 606(b)(1). View "State v. Leon" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the sentencing court following Defendant’s guilty plea to an information charging him with felony murder. The sentencing court imposed a prison sentence of twenty years, all but ten years suspended, with four years’ probation and a restitution order. On appeal, Defendant argued that his sentence was unconstitutionally disproportionate and denied his constitutional right to equal protection. The Supreme Judicial Court disagreed, holding (1) Defendant’s offense and sentence did not generate an “inference of gross disproportionality”; and (2) notwithstanding the fact that Defendant’s codefendant received only a seven-year sentence, Defendant’s sentence did not violate Defendant’s equal protection rights. View "State v. Lopez" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father’s parental rights to his child pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i)-(ii), holding that the court did not err in its parental unfitness and best interest determinations and that Father was not denied due process. The Court held (1) the district court did not err by determining that Father was unfit because he was unable to “meet his son’s special needs and take responsibility for him in a reasonable time to meet those needs” and to “protect his son from jeopardy in a reasonable time to meet his needs” and that termination was in the child’s best interest; and (2) Father was not denied due process. View "In re Child of James R." on Justia Law