Justia Constitutional Law Opinion Summaries

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

In Maine, former President Donald J. Trump submitted a petition for his candidacy for the Republican Party’s presidential primary. Three challengers subsequently claimed that Trump was disqualified from running because he had previously sworn to support the U.S. Constitution as President and then engaged in insurrection, which they argued precluded him from holding office under Section 3 of the Fourteenth Amendment. The Secretary of State held a hearing and decided that Trump was not qualified to appear on the ballot. Trump appealed this decision to the Superior Court, which remanded the matter back to the Secretary of State for a new ruling after the Supreme Court reaches a decision in a related case. The Secretary of State and the three challengers appealed to the Maine Supreme Judicial Court, which dismissed the appeal as interlocutory and not justiciable, holding that it was not from a final judgment. The court reasoned that uncertainties regarding issues of federal law pervaded the proceedings and were likely to require additional proceedings. The court deemed that an immediate review would likely result in an advisory opinion and could cause additional delay that the existing interlocutory order might avoid. View "Trump v. Secretary of State" on Justia Law

In the case before the Maine Supreme Judicial Court, Dana A. Healey appealed his conviction for domestic violence assault. Healey argued that the trial court exceeded its discretion by not allowing him or his attorneys to conduct a voir dire examination of the jury and by denying his requests to cross-examine the victim about her recanted domestic violence allegation against another person and the text messages that she sent to Healey after his arrest. Healey contended that these rulings violated his constitutional rights to a jury trial and to confront witnesses against him.The court acknowledged Healey's concerns but ultimately affirmed the trial court's decision. The court found that the trial court did not abuse its discretion when it denied Healey’s request to cross-examine the victim about her recanting a domestic violence allegation against another person. The court also found that the trial court erred in excluding at least one of the victim’s text messages to Healey: the message stating, “We’re even.” However, the court determined that, despite this error, there was sufficient, independent evidence to support the jury's verdict.The court based its decision on the testimony of the responding officer and a witness who saw the incident, as well as the 9-1-1 call made by the witness. These pieces of evidence, the court concluded, provided sufficient support for the jury's verdict, regardless of the excluded text messages. Therefore, the court was satisfied beyond a reasonable doubt that the excluded evidence would not have affected the jury's verdict. As such, the court affirmed Healey's conviction and sentence. View "State of Maine v. Dana A. Healey" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court denying Petitioner's petition for post-conviction review (PCR) arguing that her trial counsel provided ineffective assistance, holding that Petitioner's conviction of domestic violence assault against her daughter must be vacated.In her PCR petition, Petitioner argued that trial counsel's representation was ineffective by opening the door during opening statements to prejudicial evidence about her parenting practices and because he did not object to prosecutorial error at trial. The PCR denied relief. The Supreme Judicial Court vacated the judgment below, holding that trial counsel's decision to open the door to evidence regarding Petitioner's parenting practices and his failure to object at trial to the prosecutorial error made his conviction unreliable and unworthy of confidence. View "Pratt v. State" on Justia Law

The Supreme Judicial Court affirmed the decision of the Commissioner of the Department of Inland Fisheries and Wildlife to revoke or suspend Appellant's hunting license for three years and his guide license for one year, holding that there was no error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the Commissioner’s interpretation of the statute mandating revocation of Appellant's hunting license for one year was correct, and her action revoking Appellant's hunting license for one year was supported by substantial evidence; (2) Appellant did not overcome the presumption of constitutionality to demonstrate that the statute governing hunting license revocation and suspension was constitutionally vague; and (3) the Legislature acted within constitutional bounds in delegating authority to the Commissioner to establish standards of competency for licensed guides. View "Wood v. Dep't of Inland Fisheries & Wildlife" on Justia Law