Justia Constitutional Law Opinion Summaries

Following a jury trial, Appellant was convicted of manslaughter, aggravated criminal operating under the influence, aggravated leaving the scene of a motor vehicle accident, and operating under the influence. The Supreme Court affirmed, holding (1) the evidence produced at trial permitted a rational jury to find Appellant guilty beyond a reasonable doubt on each of the counts in the indictment; and (2) the court did not err in failing to presume prejudice after an attempted jury tampering, failing to issue a curative instruction after an improper comment by the State, and prohibiting Appellant from impeaching a witness with an audio recording of prior inconsistent statements. View "State v. Cheney" on Justia Law

Plaintiff filed a complaint against her former employer, Adroscoggin County, alleging gender discrimination, constructive discharge, and retaliation. The superior court granted partial summary judgment in favor of the County dismissing the counts of constructive discharge and gender discrimination. The retaliation claim proceeded to trial, and the jury returned a verdict for the County. Plaintiff subsequently appealed from the partial summary judgment dismissing the constructive discharge claim. The Supreme Court affirmed, holding (1) notwithstanding its application in the labor and discrimination contexts, constructive discharge does not exist as an independent cause of action under Maine statutory or common law; and (2) because Plaintiff did not challenge the summary judgment denying her claim for gender discrimination or the judgment entered on the jury's verdict denying her claim for retaliatory discrimination, nor did Plaintiff allege that the actions giving rise to her alleged constructive discharge from employment were themselves a form of unlawful discrimination under the Maine Human Rights Act, Plaintiff's claim for constructive discharge failed. View "Levesque v. Androscoggin County" on Justia Law

Paul Clark obtained a temporary protection from abuse order on behalf of his thirteen-year-old son against Defendant Michelle Fundalewicz, the child’s mother and Paul’s ex-girlfriend. At the time, the child resided with Paul and Paul’s then-fiancée (now wife), Miranda Clark. The child received a phone call on the home’s landline while Paul or both Paul and Miranda were not home. The child eventually revealed that Defendant had called him earlier that day. Paul reported the incident to the police. The child provided a written statement to the police stating that Defendant did call and speak with him. The State charged Defendant with violation of a protection order; Defendant pled not guilty to the charge and the matter proceeded to a jury-waived trial. At trial, the child testified that it was instead his cousin who called him. He testified that he said it was Defendant in his written statement to police because Paul had told him that if he did not name Defendant, the child would have to move back in with his mother where he would "get treated like crap" as he had been when he lived with her in the past. Miranda testified that a few days after the incident, she spoke with Defendant on the phone, and Defendant admitted to having called and spoken with the child. At the close of the trial, Defendant orally moved for a judgment of acquittal on the grounds that "the State failed to establish a corpus for the offense charged" because the State did not provide "evidence independent of any potentially incriminating statements that [Fundalewicz] . . . made." The court denied the motion, found Defendant guilty of violating the protection order, and sentenced her to pay a $400 fine. Although largely circumstantial, the Supreme Court concluded that the evidence presented at trial, along with the reasonable inferences that could have been drawn from it, adequately supported the corpus delicti requirement, as well as the court’s finding that Defendant did in fact call her son in violation of the protection order.

Daniel Whitney appealed his conviction on one count of operating under the influence following his conditional guilty plea. Whitney argued on appeal that the trial court erred in issuing an order denying his motion to suppress evidence derived from a police officer's stop of his vehicle. Because the Supreme Court concluded that the stop was unconstitutional, it vacated the judgment and the order denying the motion to suppress.

Defendant Tammy Bragg appealed her conviction for operating under the influence following a jury trial. On appeal, Defendant contended that the court erred when it refused to suppress statements she made at the scene of the accident and at the police station. After review of the trial court record, the Supreme Court affirmed the judgment.

Defendant Aaron J. Patton appealed his conviction following a jury trial at which he was found guilty of four counts of gross sexual assault; one count of unlawful sexual contact; and two counts of sexual abuse of a minor. Upon review, Defendant contended that the court erred in several respects, including: (1) a constitutional error resulting from the court's decision to permit a State's witness (a police officer) to testify over his objection about Defendant's assertion of his right to remain silent shortly before his arrest; (2) the admission of evidence of Defendant's use of hypnosis; (3) the admission of police officer testimony that contained inadmissible hearsay evidence and was unfairly prejudicial; and (4) the misstatement of jury instructions. Upon review of the superior court record, the Supreme Court disagreed and affirmed the judgment.

William Weber, Jr. appealed a protection from abuse order entered in district court on a complaint filed by Maureen O'Brien on behalf of her sixteen year old daughter. Weber contended that the court lacked authority to enter a new protection order based solely on the same act of abuse that was the subject of an expired, unextended protection order between the same parties. Upon review, the Supreme Court agreed and vacated the judgment.

Defendant Rachel Prescott appealed her conviction following a conditional guilty plea to operating while under the influence and for failing to report an accident. Defendant's plea preserved her right to appeal the trial court's order that denied her motion to suppress evidence derived from police questioning. Defendant argued on appeal that she was not technically in police custody at the time she was questioned because she was not read her rights nor did the police use its crusier lights when transporting her from the scene of the accident. Upon review, the Supreme Court concluded Defendant was in custody at the time of her questioning, and vacated the judgment and part of the suppression order entered in Defendant's case.

Defendant Colin Haag appealed his conviction on two counts of kidnapping after a jury trial at superior court. Defendant was charged with kidnapping stemming from divorce proceedings through which Defendant's ex-wife withheld access to Defendant's two daughters. On appeal, Defendant contended that the evidence presented at trial was insufficient to support his convictions and that the court erred in denying his motion for judgment of acquittal. Upon review of the superior court record, the Supreme Court found the evidence sufficient to support Defendant's conviction, and affirmed the superior court's judgment.

After a jury trial, Defendant Colin Koehler was found guilty of the intentional or knowing murder of a young woman he had known for less than a day, for which the court sentenced him to life in prison. On appeal, Defendant challenged several rulings on evidence, procedure, motions, and jury instructions. He also challenged his sentence primarily on the grounds that there was insufficient evidence of premeditation, that he has no substantial criminal history, and that his mental health evaluations failed to reveal any significant psychological or psychiatric disorders linked to criminality. Upon review, the Supreme Court found no error in the trial court’s rulings and concluded that the court acted within its sentencing authority in imposing a life sentence.