Justia Constitutional Law Opinion Summaries

Articles Posted in Maine Supreme Court

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After a jury trial, Defendant was convicted of unlawful sexual contact and unlawful sexual touching. This was the third trial held after two mistrials in this case. The Supreme Court affirmed, holding that the trial court did not err in (1) delcaring a mistrial at the second trial; (2) denying Defendant's motion for a new trial filed after the third trial on grounds of prosecutorial misconduct in the prosecutor's gestures during the third trial, which Defendant claimed telegraphed the prosecutor's personal opinion or witness credibility; and (3) failing to limit, on its own initiative, alleged misstatements of law and fact that the prosecutor made in closing argument and in rebuttal at the third trial. View "State v. Carey" on Justia Law

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Defendant pled guilty to unlawful trafficking in a scheduled drug. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence obtained from a warrantless administrative inspection of a bus on which he was a passenger and a search of his person. The Supreme Court affirmed, holding that even if the police violated the Fourth Amendment while conducting the warrantless administrative inspection of the bus, the court did not err in denying Defendant's motion to suppress, as Defendant's voluntary consent to a dog sniff was sufficiently attenuated from the bus inspection, and the dog's alert on Defendant constituted sufficient probable cause for the agents to proceed with the search of Defendant's person. View "State v. Ntim" on Justia Law

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Since 2001, Callaghan has worked part-time at the South Portland Library. Edwards works for the Parks and Recreation Department about four hours per week. Both are subject to a personnel policy, which, following 2010-2011 amendments, provides that city employees may not seek or accept nomination or election to any South Portland elective office; use the influence of their employment for or against any candidate for city elective office; circulate petitions or campaign literature for any city elective office; solicit or receive subscriptions, contributions or political service from any person for or against any candidate for any city elective office; or use city property to assist or advocate for or against any candidate. Callaghan has served on the School Board since 2007. When Callaghan sought reelection in 2011, the City Clerk stated that the personnel policy amendments prevented placement of her name on the ballot. Edwards had served on the Board for 18 years. In 2010, Edwards expressed interest in filling a vacancy on the Board. After the City Clerk questioned whether Edwards could be appointed given his city employment, Edwards did not pursue the appointment. Edwards and Callaghan filed a complaint, 42 U.S.C. 1983, asserting that the policy was an unconstitutional restraint on political speech. The trial court entered partial summary judgment for the employees and an injunction barring enforcement of a prohibition on any city employee seeking election to or serving on the School Board or, on their own time, from circulating petitions or campaign literature and soliciting or receiving contributions or political service for or against candidates in School Board elections. The Maine Supreme Court affirmed as to the employees, but vacated the judgment to the extent that it invalidates the policy as to employees who were not parties. View "Callaghan v. City of South Portland" on Justia Law

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After a jury trial, Defendant was convicted of murder and sentenced to a term of thirty-eight years incarceration. Defendant subsequently filed two motions for a new trial, both of which were denied. Defendant appealed, asserting that the State's alleged failure to disclose evidence pursuant to Brady v. Maryland and the discovery of new evidence after trial entitled him to a new trial. The trial court denied both motions. The Supreme Court affirmed, holding (1) the undisclosed evidence, although helpful to Defendant, did not undermine confidence in the jury's verdict; and (2) to the extent that the newly discovered evidence would be admissible at a new trial, it consisted primarily of impeachment evidence that was cumulative of the evidence the jury heard at trial or concerned a witness not critical to the State's case, and therefore, it was not clear the evidence would change the outcome of the trial. View "State v. Twardus" on Justia Law

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Defendant entered a conditional guilty plea to aggravated operating after habitual offender revocation, operating after habitual offender revocation, and criminal OUI. Defendant appealed, arguing, inter alia, that the lower court erred in denying his motion to suppress because the officer who stopped his vehicle lacked an objectively reasonable suspicion for stopping his vehicle. The Supreme Court affirmed, holding (1) the record supported the conclusion that the officer who stopped the vehicle Defendant was operating had a subjective and objectively reasonable suspicion that the operator of the vehicle was operating while under the influence of intoxicants; and (2) the lower court did not err in declining to dismiss the charges arising from operating after revocation. View "State v. Spiegel" on Justia Law

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After a jury trial, Defendant was convicted for multiple offenses of unlawful sexual contact, unlawful sexual touching, and assault. On appeal, Defendant challenged, inter alia, the trial court's denial of his motion to suppress evidence obtained from his computer pursuant to a search warrant. The Supreme Court affirmed, holding (1) the court did not err in denying Defendant's motion to suppress, as (i) the search warrant was supported by probable cause, and (ii) a clerical error in the jurat of the warrant affidavit did not affect the validity of the search warrant; and (2) the trial court did not clearly err in admitting testimony concerning sexually suggestive websites that Defendant viewed on his home and work computers. View "State v. Vrooman" on Justia Law

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Defendant pleaded guilty to the intentional or knowing murder of his wife. The sentencing court imposed a final sentence of forty years in prison. Defendant appealed his sentence. The Supreme Court affirmed, holding (1) the sentencing court did not err in applying the first step of the sentencing analysis required by Me. Rev. Stat. 17-A, 1252-C(1) in setting Defendant's basic sentence; (2) Defendant's argument that availability of basic sentence information implicates all criminal defendants' equal protection and due process rights failed; and (3) the court appropriately considered objective, factually reliable information in placing Defendant's conduct along a continuum of seriousness. View "State v. Nichols" on Justia Law

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After a jury-waived trial, Defendant was convicted of operating under the influence of intoxicants (OUI) with one previous OUI conviction within a ten-year period. Defendant appealed, contending that the court erred in denying his motion to suppress evidence of a horizontal gaze nystagmus (HGN) test and the events that followed and in applying the corpus delicti rule as modified by Me. Rev. Stat. 29-A, 2431(4). The Supreme Court affirmed, holding (1) because Defendant was not subject to an unlawful arrest when the HGN test was administered, the trial court did not err in denying Defendant's motion to suppress; and (2 )the trial court reasonably inferred that a statement made by Defendant was an admission of driving, and the statement was sufficient to establish that Defendant operated a vehicle without further proof of corpus delicti. View "State v. White" on Justia Law

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After a jury trial, Defendant was convicted of reckless conduct with a dangerous weapon. Applying the minimum mandatory sentencing provision of Me. Rev. Stat. Ann. 17-A, 1252(5), apparently on its own initiative, the trial court sentenced Defendant to one year in prison. The Supreme Court affirmed the conviction but vacated the sentence imposed, holding (1) the evidence was sufficient to support the conviction; (2) the trial court did not err in excluding or limiting certain evidence Defendant sought to introduce through a lay witness, a private investigator; (3) the trial court did not abuse its discretion when it denied Defendant's motion for a mistrial and instead provided a curative instruction in response to a comment the prosecutor made in rebuttal; and (4) because the parties agreed that the court should reconsider the sentence, the sentence should be vacated. Remanded for resentencing. View "State v. Kline" on Justia Law

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The Commission on Governmental Ethics and Election Practices subpoenaed documents and testimony from the National Organization for Marriage (NOM) seeking the names of donors to NOM in order to determine whether NOM had complied with Maine's campaign laws during the 2009 election season. The superior court affirmed the Commission's decision not to vacate or modify the subpoenas. Appellants, including NOM and Stand for Marriage Maine PAC, appealed, contending that the Commission's subpoenas infringed on their right to freedom of association because disclosure would expose NOM's donors to threats, harassment, and reprisal. The superior court affirmed. The Supreme Court also affirmed, concluding that the record did not support Appellants' constitutional argument. View "Nat'l Org. for Marriage v. Comm'n on Governmental Ethics & Election Practices" on Justia Law