Justia Constitutional Law Opinion Summaries

After Father tested positive three times for marijuana use in violation of conditions of probation, the Department of Health and Human Resources removed Father's son, T.B., from Father's care. Father was incarcerated for a third time during a reunification period with T.B., and the Department subsequently filed a petition to terminate Father's parental rights. Father moved for substitution of court-appointed counsel, which the district court denied on the grounds that the trial was to start in two days. After a three-week continuance, the trial was held, and the court terminated Father's parental rights. Father appealed, contending that he was denied due process when the district court did not, on its own initiative, inform him that he could proceed without counsel after denying his motion to dismiss his current counsel or his implicit motion to appoint new counsel. The Supreme Court affirmed, holding that, under the circumstances of this case, the trial court did not err in its judgment. View "In re T.B." on Justia Law

Defendant pleaded guilty to four counts of unlawful sexual contact. The Supreme Court vacated the sentences imposed on Defendant. On remand and after a hearing, the superior court imposed consecutive sentences on each of the counts for an overall sentence of twenty-seven years in prison. Defendant challenged his sentence on appeal, arguing that his overall sentence was excessive. The Supreme Court vacated the sentence and remanded for resentencing, holding that, by imposing a sentence that included twenty-seven unsuspended years of incarceration, the superior court exceeded its discretion because the overall sentence was far out of line with sentences of other defendants convicted of unlawful sexual contact. View "State v. Stanislaw" on Justia Law

After a jury-waived trial, Defendant was convicted of assault and refusing to submit to arrest. Defendant appealed, arguing that the trial court erred in determining that he was competent to stand trial. The Supreme Court affirmed, holding (1) the evidence presented at the competency hearing - namely, Defendant's own testimony - was sufficient to support the court's determination, by a preponderance of the evidence made after the competency hearing, that Defendant was competent to stand trial; (2) the trial court did not err in failing to reconsider Defendant's competency during the trial itself; and (3) Defendant's remaining considerations were without merit. View "State v. Nickerson" on Justia Law

Defendant pleaded guilty to operating under the influence. Defendant moved to suppress all evidence obtained from the stop of his vehicle for lack of reasonable articulable suspicion. The trial court agreed that the police trooper, who followed Defendant's car into a business park and interacted with Defendant after he stopped his vehicle, lacked the required reasonable articulable suspicion. The Supreme Court vacated the portion of the trial court's decision granting Defendant's motion to suppress, holding that the lower court erred in determining that the trooper seized Defendant by following him into the park, as Defendant was not subject to physical force or show of authority. Remanded. View "State v. Collier" on Justia Law

Following a jury trial, Defendant was convicted of one count of arson. The Supreme Court affirmed the judgment of conviction, holding (1) the indictment and jury verdict did not deprive Defendant of his constitutional right to be free of double jeopardy because the trial court consolidated two separate counts of arson based on one criminal act identified in the indictment and jury verdict and sentenced Defendant for only one count of arson; and (2) under the circumstances, the trial court did not deprive Defendant of his Sixth Amendment right to counsel when it overruled Defendant's objection to the testimony of an anticipating defense witness who decided, mid-trial, to testify for the prosecution in exchange for a promise of immunity. View "State v. Bellavance" on Justia Law

After a jury trial, Defendant was convicted of seven counts of unlawful sexual contact (Class C) and three counts of unlawful sexual contact (Class B). Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to a detective because he was not advised of his Miranda rights prior to his custodial interrogation and because his statements made prior to and after his arrest were involuntary. The Supreme Court vacated the judgment of conviction and remanded, holding (1) Defendant was not in custody for purposes of the Miranda requirements; but (2) the district court clearly erred in finding that Defendant's statements were voluntary. View "State v. Wiley" on Justia Law

The Town of Madawaska foreclosed on Jeffrey and Jeanne Stoops' property after the Stoops failed to pay municipal taxes. The Town then conveyed the property to Richard and Betty Nelson by municipal quitclaim deed. The Stoopses subsequently filed a complaint against Richard Nelson seeking to quiet title to the property and asking the court to declare the respective rights of the parties to the property. The superior court granted the Nelsons' motion for summary judgment. The Stoopses appealed, arguing (1) the Town failed to give the Stoopses proper notice of the pending foreclosure in violation of their due process rights, and (2) the Town failed to adhere strictly to the requirements of the statutorily outlined steps a municipality must take to foreclose on a municipal tax lien. The Supreme Court affirmed, holding that because the Town complied with the requirements of the statutory scheme and gave the Stoopses sufficient notice, the trial court correctly granted summary judgment in favor of the Nelsons. View "Stoops v. Nelson" on Justia Law

Plaintiffs were sex offenders who were all initially required to register as sex offenders under Maine's Sex Offender Registration and Notification Act (SORNA) of 1999. Some Plaintiffs were later relieved of the registration requirement, but others remained on the registry and had viable claims. Plaintiffs filed actions against several State defendants, alleging, among other things, that SORNA of 1999 was an unconstitutional ex post facto law. The trial court granted the State defendants' motion for summary judgment, concluding that the cases of the Plaintiffs who successfully petitioned to be relieved from the duty to register were moot and that SORNA of 1999 as amended after State v. Letalien was constitutional. The Supreme Court affirmed the trial court's decision that SORNA of 1999 as amended following the Court's decision in Letalien did not violate the constitutional rights of the litigants. View "Doe v. Williams" on Justia Law

Defendant was charged by a fifty-nine-count indictment that included forty-five counts of violation of privacy and one count of conspiracy to commit violation of privacy. Defendant subsequently filed a motion to dismiss the violation of privacy counts, which the trial court granted, concluding that based on the indictment and the State's offer of proof, the State could not prove the crimes as alleged. The State appealed, contending that the court erred in granting the motion because it was untimely and the indictment adequately charged the offenses pursuant to the applicable statutes. The Supreme Court affirmed, holding that because the relevant counts of the indictment, as augmented by the State's offer of proof, failed adequately to charge the offense of violation of privacy, the court properly granted Defendant's motion to dismiss. View "State v. Strong" on Justia Law

Defendant and two co-conspirators pleaded no contest or guilty to various charges. Defendant pleaded guilty to two counts of intentional or knowing murder. The sentencing court sentenced Defendant to two concurrent terms of forty-five years in prison. Defendant appealed, arguing that the court abused its discretion in sentencing him to a longer prison term than that of his two co-conspirators. The Supreme Court affirmed the sentences, holding that, given the court's consideration of the purposes of sentencing, proper completion of the two-step sentencing procedure for murder, articulation of the reasons for the sentence, and explicit discussion of and adjustment for the sentencing inequality at issue, the sentencing court did not abuse its discretion in sentencing Defendant. View "State v. Hamel" on Justia Law