Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of two counts of gross sexual assault, two counts of aggravated assault, and other charges. The Supreme Judicial Court affirmed the judgment, holding that the trial court (1) did not deprive Defendant of a fair trial by denying his motion for sanctions and a continuance based on the State’s late disclosure of the victim’s medical records; (2) did not violate Defendant’s right of confrontation when it admitted a recorded interview of the victim; and (3) did not deprive Defendant of a fair trial by precluding him from calling two late disclosed witnesses not included on the witness list described to the jury. View "State v. Gagne" on Justia Law

In 2014, the City Council of South Portland enacted an ordinance prohibiting the bulk loading of cure oil on marine tank vessels in South Portland. In 2015, the Portland Pipeline Corporation and American Waterways Operators (PPLC) sued the City of South Portland and its Code Enforcement Officer in federal court, arguing that the ordinance was unconstitutional. The complaint requested only nonmonetary relief. The City notified the Maine Municipal Association Property & Casualty Pool (Pool), which provides liability coverage to the City and its public officials, of the lawsuit and requested a defense, which the Pool declined to provide. The City then brought this action alleging breach of the duty to defend. The superior court granted summary judgment for the Pool, concluding that the Pool had no duty to defend because the complaint requested only declaratory and injunctive relief, not damages, and therefore, there was no potential that the City could be liable for damages within the scope of coverage. The Supreme Judicial Court affirmed on different grounds, holding that the Pool had no duty to defend because any potential damages would be excluded from coverage. View "City of South Portland v. Maine Municipal Association Property & Casualty Pool" on Justia Law

Defendant was charged with operating under the influence. After a trial, the court concluded that the jury was genuinely deadlocked and sua sponte declared a mistrial due to manifest necessity. Defendant then moved to dismiss the criminal complaint against him on double jeopardy grounds and on the grounds that the prosecutor had committed misconduct. The court denied Defendant’s motion to dismiss, concluding that the double jeopardy clauses of the federal and state constitutions did not bar a second prosecution and that there had been no prosecutorial misconduct. The Supreme Judicial Court affirmed, holding (1) there was a manifest necessity for a mistrial due to a genuinely deadlocked jury; and (2) Defendant’s allegations of prosecutorial misconduct were unfounded. View "State v. Jandreau" on Justia Law

Defendant was charged by complaint with operating under the influence based in part on an allegation of a blood test measuring 0.15 grams of alcohol per 100 milliliters of blood. Defendant moved to suppress the evidence obtained through the blood test. The trial court granted the motion to suppress, finding that the police officer did not obtain a warrant or seek Defendant’s consent, that Defendant did not consent to the blood test, and that there were no exigent circumstances generating an exception to the warrant requirement. The State appealed. The Supreme Judicial Court affirmed, holding that the record did not compel a finding that Defendant objectively manifested consent to the drawing and testing of his blood through his mere acquiescence and cooperation. View "State v. Boyd" on Justia Law

After a jury trial, Defendant was convicted of theft by unauthorized taking or transfer and theft by deception. Defendant appealed, arguing (1) the evidence presented at trial was insufficient to support the convictions, and (2) the trial court violated her right to be free from double jeopardy by convicting and sentencing her on both counts of theft without consolidating them. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support both convictions; and (2) the trial court did not err by entering a judgment of conviction on each count of theft or by sentencing Defendant on both counts of theft, and furthermore, there was no violation of Defendant’s right to be free from double jeopardy because the convictions and sentences were not based on a single criminal act. View "State v. Hayward" on Justia Law

Defendant pleaded guilty to three counts of gross sexual assault and two counts of unlawful sexual contact. The court sentenced Defendant to twenty years’ imprisonment followed by fifteen years of supervised release. Defendant challenged his sentence on appeal, arguing, inter alia, that the supervised release sentencing process, mandated by law, violates the due process clause and the double jeopardy clause. The Supreme Judicial Court affirmed, holding (1) Defendant’s due process argument actually addresses the length of his total sentence, and the sentence is not constitutionally disproportionate or cruel or unusual punishment; (2) the supervised release sentencing process does not violate the Double Jeopardy Clause; and (3) the supervised release statutory scheme does not abrogate the traditional Hewey analysis. View "State v. Parker" on Justia Law

After a jury trial, Defendant was convicted of baiting deer and hunting from an observation stand overlooking deer bait. The Supreme Court affirmed, holding (1) the instructions given by the trial court fairly and accurately informed the jury of all necessary elements of the governing law, and therefore, Defendant was not deprived of a fair trial; and (2) statements by the prosecutor during his opening and closing that purported to explain that hunting regulations and statutes were premised on a need to keep a level playing field among hunters were improper, but the error was not plain, nor did the error affect Defendant’s substantial rights or the outcome of the trial. View "State v. Lajoie" on Justia Law

Defendant entered a conditional guilty plea to a charge of unlawful possession of schedule W drugs, preserving his right to appeal from the denial of his motion to suppress. Defendant appealed, arguing that the trial court erred by denying his motion to suppress evidence of drugs that he was carrying in a body cavity because law enforcement officers exceeded the authority granted them by two search warrants explicitly authorizing a search of Defendant’s person. The Supreme Court affirmed, holding that, under the facts of this case, the trial court did not err in denying the motion to suppress. View "State v. Cooper" on Justia Law

The district court issued a warrant authorizing officers to search Defendant’s residence. The search resulted in the seizure of container of “Molotov cocktails” and a handgun. Defendant moved to suppress the evidence arguing that the search warrant was tainted by an unlawful initial search relying on an affidavit that failed to supply probable cause that evidence of illegal drug activity would be found at the property. The superior court denied the motion to suppress. Pursuant to a conditional guilty plea, Defendant was convicted of one count of arson and two counts of criminal threatening. Defendant appealed the denial of his motion to suppress, arguing that, because it was objectively unreasonable for an officer to believe the search warrant established probable cause, the court erred in applying the good faith exception to the exclusionary rule. The Supreme Court affirmed, holding that the issuing judge had a substantial basis to find probable cause for the warrant to issue. View "State v. Nunez" on Justia Law

After a jury trial, Defendant was convicted of two counts of unlawful sexual contact. The trial court imposed concurrent sentences of three years’ imprisonment with all but fifteen months suspended and eight years of probation. Defendant appealed, arguing that the trial court erred by rejecting Defendant’s request for a specific unanimity instruction and that the State made improper statements in its closing argument that, even in the absence of an objection, warranted a new trial. The Supreme Judicial Court vacated the judgment, holding (1) the omission of the specific unanimity instruction was prejudicial to Defendant; and (2) the State made improper comments to the jury during closing argument. Remanded for a new trial. View "State v. Hanscom" on Justia Law