Justia Constitutional Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court affirmed Defendant's conviction for certain domestic violence incidents, including possession of a firearm by a prohibited person, holding that Defendant was not entitled to relief on his allegations of error.After a jury convicted him of six offenses Defendant appealed, raising several allegations of error. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant's request for sanctions for the State’s alleged discovery violations; (2) the trial court did not commit obvious error by admitting testimony of a police officer, including certain statements under Me. R. Evid. 801(d)(1)(B); (3) the trial court did not abuse its discretion in admitting an unauthenticated letter that Defendant claimed was written on behalf of the victim; (4) the court did not err when it denied Defendant's motion to dismiss because of the makeup of the jury venire; and (5) there was sufficient evidence for the jury to have rationally found that every element of each count Defendant was convicted of was proved beyond a reasonable doubt. View "State v. Thomas" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court suppressing Defendant's blood test results in the State's prosecution of Defendant for operating under the influence, holding that the findings of the court did not support its legal conclusion that Defendant did not voluntarily give his consent.In suppressing the blood test results the trial court concluded that the blood draw was a result of simple acquiescence to the trooper's authority. On appeal, the State argued that the trial court erred in concluding that Defendant did not voluntarily consent to the blood draw. The Supreme Judicial Court agreed and reversed the the trial court's order suppressing the evidence, holding that, in the totality of the circumstances, holding that Defendant's response to the trooper's request objectively manifested free and voluntary consent. View "State v. Croteau" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights as to his child, holding that Father was not denied due process and that Father failed to prove his claim of ineffective assistance of counsel.After a hearing, the district court entered an order terminating the parental rights of Mother and Father to their child finding that the parents were unwilling or unable to protect the child from jeopardy or to take responsibility for the child in a time reasonably calculated to meet the child's needs and that termination was in the child's best interest. The Supreme Judicial Court affirmed, holding (1) the trial court's decision to accept a proposed order and findings only from the Department of Health and Human Services did not affect the outcome of the case; and (2) Father was not entitled to relief on his ineffective assistance of counsel claim. View "In re Child of Kenneth S." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of intentional or knowing murder, holding that there was no error.On appeal, Defendant argued that the trial court erred in denying his motion to dismiss the indictment for failure to comply with the Interstate Compact on Detainers and violated his constitutional rights by holding bench conferences in the hallway and by denying his motion to represent himself. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to dismiss based on the Compact; (2) Defendant failed to show obvious error on his argument that holding bench conferences in the hallway violated his public trial rights; and (3) the trial court did not err or abuse its discretion when it denied Defendant's mid-trial request to represent himself. View "State v. Reeves" on Justia Law

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The Supreme Judicial Court vacated Defendant's conviction for intentional or knowing murder entered in the trial court following a jury trial, holding that the trial court erred in denying Defendant's motion to suppress evidence and statements that were obtained in violation of Defendant's constitutional rights.In denying Defendant's motion to suppress, the trial court determined that the searches of Defendant's property were not unreasonable because the emergency aid doctrine supported the searches, that suppression would not be justified even if they were, and that Defendant's statements were made voluntarily. The Supreme Judicial Court vacated the judgment of conviction, holding that Defendant's rights under the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution and Me. Const. art. I, 6, 6-A were violated, and that the trial court erred in denying Defendant's motion to suppress. View "State v. Akers" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction and sentence for knowing or intentional murder and the denial of his motion for a new trial, holding that there was no error.On appeal, Defendant argued that the trial court erred or abused its discretion in excluding alternative-suspect evidence, failing to provide an adequate explanation in setting the basic sentence, and denying his motion for a new trial based on a juror's statements made after Defendant's conviction. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion in excluding alternative-suspect evidence as insufficient to establish a reasonable connection to the crime; (2) the court did not misapply sentencing principles in setting a basic sentence of forty to forty-five years' incarceration; and (3) the court did not err or abuse its discretion in denying Defendant's motion for a new trial. View "State v. Daly" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment against the Portland Regional Chamber of Commerce on its claims that voter-initiated legislation establishing an emergency minimum wage in Portland violated the Portland City Code and the Maine Constitution, holding that there was no error.After voters approved the initiative at issue, Plaintiffs, employers with employees in Portland, filed a complaint asserting that the initiative was invalid and that, if it was valid, it would not take effect until January 1, 2022. Intervenors filed a cross-claim seeking declaratory relief establishing the effective date of the emergency provision as December 6, 2020. The superior court concluded that the emergency provision was validly enacted pursuant to the Maine Constitution and the Portland City Code and dismissed Intervenors' cross-claims. The Supreme Judicial Court affirmed, holding (1) the initiative was validly enacted; and (2) the emergency provision was effective as of January 1, 2022. View "Portland Regional Chamber of Commerce v. City of Portland" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for intentional or knowing murder and sentence of forty years' imprisonment, holding that there was no error in the proceedings below.Specifically, the Supreme Judicial Court held that the trial court (1) did not err in determining that Defendant had waived the religious privilege in relation to a communication he made to church leaders; (2) did not err by declining to give Defendant's requested jury instruction that the State was required to prove that he intentionally or knowingly killed the victim and not just intentionally or knowingly killed another human being; (3) did not err when it denied Defendant's motion to continue the sentencing hearing; and (4) misapplied no legal principles and acted within its discretion in sentencing Defendant. View "State v. Gaston" on Justia Law

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The Supreme Judicial Court vacated the judgment entered by the superior court denying in part Petitioner's petition for post-conviction review of his conviction on several sexual assault charges, holding that Petitioner was deprived of his right to the effective assistance of trial counsel.After a trial, the jury found Petitioner guilty of one count each of gross sexual assault, unlawful sexual contact, and sexual abuse of a minor. The Supreme Court affirmed. Petitioner subsequently filed a postconviction petition arguing that he had been deprived of his right to the effective assistance of counsel. The Supreme Court granted the petition as to the convictions for unlawful sexual contact and sexual abuse of a minor and vacated Petitioner's convictions on those counts but denied Petitioner's petition as to the conviction for gross sexual assault. The Supreme Judicial Court vacated the judgment and remanded for entry of a judgment granting Petitioner's petition for post-conviction review and vacating the remaining conviction, holding that counsel's performance was deficient and that Petitioner was entitled to post-conviction relief from the remaining portion of the judgment of conviction. View "Hodgdon v. State" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court affirming the Department of Public Safety's denial of Appellant's application for a professional investigator license, holding that Appellant's First Amendment rights were not violated by the application of statutory competency standards to his conduct on social media.The Department denied Appellant's application based on comments and posts that he had made on social media using an account bearing the name of his out-of-state private investigation business concerning a police lieutenant. The Supreme Judicial Court affirmed the circuit court's affirmation of the Department's decision, holding (1) intermediate scrutiny applies to the Department's application of the licensing statutes to Appellant's application; (2) the Department did not err in its findings; and (3) the Department's application of the licensing standards to Appellant did not violate the First Amendment. View "Gray v. Department of Public Safety" on Justia Law