Justia Constitutional Law Opinion Summaries

Calixte Fleury was convicted of aggravated trafficking, unlawful trafficking, unlawful possession of scheduled drugs, and operating under the influence. On September 18, 2020, Fleury was driving on I-95 when he crashed his vehicle. A responding sergeant found Fleury with a bag of pills containing fentanyl and tramadol, and later discovered more fentanyl and cash on Fleury. Fleury's blood alcohol content was 0.093 grams per 100 milliliters. He was indicted and later charged with multiple counts, including aggravated trafficking and unlawful trafficking of scheduled drugs.The trial court (York County, Martemucci, J.) held a jury trial, resulting in guilty verdicts on all four criminal counts. The court found in favor of Fleury on the criminal forfeiture count. Fleury was sentenced to seven years with all but four years suspended for aggravated trafficking, three years for unlawful trafficking, and 30 days for operating under the influence, with some sentences running concurrently. The court merged the unlawful possession count with the unlawful trafficking count.The Maine Supreme Judicial Court reviewed the case. Fleury argued that the application of a repealed definition of "traffick" was unconstitutional. The court disagreed, stating that the repealed statute was rationally related to controlling opioids and its application was not unconstitutional. The court also noted that the amended statute did not apply retroactively to Fleury's case.However, the court found that the trial court should have merged the aggravated trafficking count with the unlawful trafficking and possession counts for sentencing. The Maine Supreme Judicial Court vacated the sentence and remanded for resentencing, affirming the convictions in all other respects. View "State of Maine v. Fleury" on Justia Law

Taylor M. appealed a judgment from the District Court terminating her parental rights to her child, arguing that her due process rights were violated and that the court failed to comply with the Indian Child Welfare Act (ICWA). The child, born prematurely with various medical conditions, required extensive care. Taylor M., a registered member of the Mi’kmaq Nation, was largely absent during the child’s initial hospitalization. The Department of Health and Human Services filed for a child protection order, which was granted, and the child was placed with resource parents.The District Court held a jeopardy hearing in January 2023, finding clear and convincing evidence of jeopardy due to Taylor M.’s inability to care for the child. The court scheduled several hearings, but delays occurred, and the child’s resource parents moved out of state with the Department and tribe’s agreement. In October 2023, the Department filed a petition to terminate Taylor M.’s parental rights. At the consolidated hearing in January 2024, the court heard testimony from various parties, including the ICWA director for the Mi’kmaq Nation.The Maine Supreme Judicial Court reviewed the case and found that the District Court complied with ICWA requirements. The court determined that the Department made active efforts to reunify the family and that Taylor M. did not take significant steps to address the jeopardy. The court also found beyond a reasonable doubt that continued custody by Taylor M. would likely result in serious emotional or physical damage to the child. The court affirmed the termination of Taylor M.’s parental rights, concluding that the child’s placement with the resource parents was appropriate and in the child’s best interest. View "In re Child of Taylor M." on Justia Law

Robert E. Dupuis and twelve other plaintiffs filed lawsuits against the Roman Catholic Bishop of Portland, seeking damages for sexual abuse allegedly perpetrated by the Bishop’s clergy when the plaintiffs were minor children. Their claims were previously barred by the statute of limitations. The Bishop moved for judgment on the pleadings, arguing that 14 M.R.S. § 752-C(3) (2022), which purports to revive the plaintiffs’ claims, deprives the Bishop of a constitutionally protected vested right.The Business and Consumer Docket (McKeon, J.) denied the Bishop’s motions but reported its orders to the Maine Supreme Judicial Court under Maine Rule of Appellate Procedure 24(c). The court accepted the report to determine whether the retroactive application of section 752-C(3) is constitutional.The Maine Supreme Judicial Court held that the retroactive application of section 752-C(3) contravenes centuries of precedent and multiple provisions of the Maine Declaration of Rights, as well as the Constitution’s provisions regarding separation of powers. The court concluded that once a statute of limitations has expired for a claim, a right to be free of that claim has vested, and the claim cannot be revived. Therefore, section 752-C(3) is unconstitutional as applied to expired claims. The court remanded the case for further proceedings consistent with this opinion. View "Dupuis v. Roman Catholic Bishop of Portland" on Justia Law

Ramel L. Sheppard was convicted of domestic violence aggravated assault after a jury trial in which the victim did not testify. The conviction was based in part on the victim's hearsay statement to a police officer identifying Sheppard as her attacker. Sheppard appealed, arguing that the trial court erred in admitting the hearsay statement as an excited utterance and that its admission violated his rights under the Confrontation Clause of the U.S. Constitution.The trial court (Androscoggin County) admitted the victim's statement under the excited utterance exception to the hearsay rule, finding that the statement was made spontaneously and while the victim was still under the stress of the assault. The court also determined that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. The jury found Sheppard guilty on two counts, but the court later merged one count into the other and sentenced Sheppard to seven years' imprisonment, with all but forty months suspended, and three years of probation.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that the trial court did not abuse its discretion in admitting the victim's statement as an excited utterance, as the statement was made spontaneously and under the stress of the assault. The court also held that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. Therefore, the admission of the statement did not violate Sheppard's rights under the Confrontation Clause. View "State of Maine v. Sheppard" on Justia Law

Trevor I. DesRosiers was convicted by a jury in the Penobscot County Unified Criminal Docket on three counts of sexual abuse of a minor and three counts of furnishing liquor to a minor. DesRosiers appealed, arguing insufficient evidence to prove he and the victim were not married during the sexual acts and to establish the victim’s age for Counts 1-4. He also claimed prosecutorial errors in closing arguments deprived him of a fair trial.The trial court denied DesRosiers’s motion for judgment of acquittal, and the jury found him guilty on all counts. The court sentenced him to concurrent terms of forty-two months for sexual abuse and three months for furnishing liquor, with all but twenty months suspended. DesRosiers appealed the conviction.The Maine Supreme Judicial Court reviewed the case. The court found sufficient evidence to support the jury’s conclusion that DesRosiers and the victim were not married, based on the victim’s age, living situation, and the nature of their relationship. The court also found sufficient evidence to establish the victim’s age during the offenses, as she was fifteen throughout the relevant period.Regarding prosecutorial errors, the court determined that most of the prosecutor’s comments did not constitute error. However, the prosecutor’s comment on DesRosiers’s invocation of his Fourth Amendment right was deemed error but not obvious error. The court concluded that this isolated comment did not undermine the trial’s integrity or affect the verdict.The Maine Supreme Judicial Court affirmed the judgment of conviction. View "State of Maine v. Desrosiers" on Justia Law

A group of plaintiffs, including William Clardy, Michelle Tucker, two state representatives, and a nonprofit corporation, filed a lawsuit against Maine's Senate President, Speaker of the House, and Governor. They sought to invalidate a special legislative session called by the Governor, arguing it was unconstitutional. The plaintiffs claimed the session was based on a "contrived" extraordinary occasion and that the legislative leaders ceded power to the executive branch. They sought declarations that the session and the legislation passed during it were void.The Kennebec County Superior Court dismissed the complaint for failure to state a claim. The court did not decide on the plaintiffs' standing but ruled that the Governor's determination of an extraordinary occasion to convene the Legislature was not subject to judicial review. Additionally, the court found that the legislative leaders were immune from suit for their actions. The plaintiffs appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the dismissal, but on different grounds. The court held that the plaintiffs lacked standing to bring the suit. The court found that the individual plaintiffs, as citizens and taxpayers, did not demonstrate a particularized injury distinct from the general public. The state representatives failed to show a concrete injury arising from the Governor's proclamation or the convening of the special session. Lastly, the nonprofit corporation lacked standing because its members did not have standing to sue individually. The court concluded that no plaintiff had suffered an injury sufficient to confer standing, thus affirming the lower court's dismissal of the case. View "Clardy v. Jackson" on Justia Law

Corydon Judkins was convicted of domestic violence assault after a jury trial. The case revolved around an incident where the police were called to Judkins' apartment, and the victim alleged that Judkins had assaulted her. The victim's statements were recorded by the responding officer's body camera. However, the victim did not testify at the trial. The State introduced the body camera footage, including the victim's statements, as evidence. Judkins objected, arguing that his constitutional right to confront witnesses was violated as he could not cross-examine the victim. The trial court admitted the footage, citing the excited utterance exception to the hearsay rule.The Maine Supreme Judicial Court reviewed the case. The State conceded that the victim's statements were testimonial and should not have been admitted. The court agreed, stating that once Judkins was removed from the apartment, there was no ongoing emergency that would support the admission of the victim's answers as non-testimonial statements. The court found that the victim's testimonial statements were inadmissible as she did not testify at trial and Judkins had no prior opportunity to cross-examine her.The court then considered whether the error was harmless. It noted that the State relied heavily on the victim's statements in the video to prove its case, and the evidence of Judkins's guilt was not overwhelming. The court also noted that the jury had asked to review the body camera footage during its deliberations. The court concluded that it could not determine beyond a reasonable doubt that the victim's statements on the body camera recording did not affect the verdict. Therefore, the court vacated the judgment and remanded the case for further proceedings. View "State of Maine v. Judkins" on Justia Law

The case involves Roger Ouellette, who was convicted of Operating Under the Influence (OUI) following a police stop in his driveway. The police officer had observed Ouellette's vehicle crossing the center line of the road, which led the officer to suspect a violation of traffic laws. Ouellette entered a conditional guilty plea after his motion to suppress evidence obtained from the stop was denied by the trial court.The trial court found that the officer had reasonable suspicion to stop Ouellette due to his observed traffic violation. Ouellette argued that the stop was unjustified as the officer lacked reasonable suspicion of wrongdoing. However, the court determined that the stop was supported by reasonable articulable suspicion that Ouellette had violated the motor vehicle statute requiring vehicles to be operated within a single lane.On appeal, Ouellette argued that the stop was an unreasonable seizure under the Fourth Amendment because it occurred within the curtilage of his home without a warrant and without any applicable exception to the warrant requirement. The Maine Supreme Judicial Court affirmed the lower court's decision, concluding that the court's failure to grant Ouellette’s motion on that ground did not constitute obvious error and that the stop was justified based on reasonable suspicion. The court also found that Ouellette's argument regarding the stop occurring within the curtilage of his home was unpreserved and did not amount to obvious error. View "State of Maine v. Ouellette" on Justia Law

The Maine Supreme Court considered a case where Virginia and Joel Parker, a couple who secure some of their food through hunting, challenged the constitutionality of Maine's longstanding ban on Sunday hunting. The Parkers argued that the ban conflicted with the recently enacted right-to-food amendment to the Maine Constitution, which they interpreted as including a right to hunt for food.The Superior Court had dismissed the Parkers' complaint on the grounds that it failed to state a claim. On appeal, the Maine Supreme Court held that the Parkers did present a justiciable claim for a declaratory judgment, and therefore the dismissal by the Superior Court was in error.However, on the question of the constitutionality of the Sunday hunting ban, the Maine Supreme Court found that the ban did not conflict with the right-to-food amendment. The court held that while the amendment does create a limited right to hunt for food, this right does not extend to situations where hunting is illegal. Given that the Sunday hunting ban makes hunting on Sundays illegal, the court concluded that the ban falls within the 'poaching' exception provided in the amendment. Therefore, the court ruled that the Sunday hunting ban is constitutional. The case was remanded to the Superior Court for entry of judgment declaring the challenged statute to be constitutional. View "Virginia Parker v. Department of Inland Fisheries and Wildlife" on Justia Law

In this case, Jacob R. Labbe Sr. was convicted by the trial court on one count of domestic violence stalking and two counts of violation of a protective order. Labbe appealed arguing that the stalking statute was unconstitutionally vague, the evidence was insufficient to convict him of domestic violence stalking, the court erred in denying his request to dismiss the charges as de minimis, and the court made several erroneous evidentiary rulings.The Maine Supreme Judicial Court affirmed the conviction. It held that the stalking statute was not unconstitutionally vague. The court found that the statute provided a clear definition of "course of conduct" and enough evidence supported a conviction for domestic violence stalking. It further held that the court did not abuse its discretion in denying Labbe's request to dismiss the charges as de minimis. The court also found no error in the trial court's evidentiary rulings. The court concluded that the First Amendment did not require the State to prove reckless disregard on the part of Labbe for the effect of his statements on the victim, as the charge was not based on the content of Labbe's communications but rather on his persistent unwelcome contact with the victim. Therefore, the court found no error in the trial court's instructions to the jury. The conviction was affirmed. View "State v. Labbe" on Justia Law