Justia Constitutional Law Opinion Summaries

Defendant entered a conditional plea of nolo contendere to the crime of operating after suspension. A judgment of conviction was entered accordingly. Defendant appealed, arguing that the lower court erred in denying his motion to suppress because the law enforcement officer’s decision to stop his vehicle was pretextual and the stop was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding that the record supported the court’s inferred finding that the stop was supported by a reasonable articulable suspicion of a threat to public safety, and therefore, the lower court did not err in denying Defendant’s motion to suppress. View "State v. Sasso" on Justia Law

At jury selection for Frisbee’s trial on charges of unlawful sexual contact, Frisbee’s attorney saw a former client, who had no connection to the matter, in the courtroom. The spectator had spent 11 months in prison for threats against Frisbee’s attorney and his family. In addition, both the judge and the State’s Attorney had previously prosecuted the spectator, who had just been released from prison for criminal threatening involving potential juror 116, later empaneled on the case. The spectator was glaring, making gestures, and smirking. The court instructed the marshals to remove the spectator. Jury selection continued without incident. During trial the spectator reappeared, closer to juror 116. The court ordered a recess and discussed the matter with the State and Frisbee’s attorney, who reported that the spectator had been seen with a weapon. The court directed security to take the spectator through security screening and interviewed juror 116, who stated that she was “very distracted.” The court excluded the spectator from the trial. The next day, the court learned that the spectator had been in the building and had approached jurors, asking them to take a copy of a book that he had written. Frisbee’s attorney requested that the jury be sequestered. The court questioned each juror; all except juror 116 stated that they had not been distracted and all of stated that the spectator in no way would affect their ability to be fair and impartial. The court denied the request. Later, the court and the parties learned that the spectator had left his notebook at the courthouse, with a threatening statement. Frisbee unsuccessfully moved for a mistrial. The Maine Supreme Judicial Court affirmed Frisbee’s conviction and sentence, finding that he had received a fair trial. View "State of Maine v. Frisbee" on Justia Law

Defendant entered a conditional plea to the charge of operating under the influence with two prior convictions for operating under the influence. Defendant appealed the denial of his motion to suppress the evidence obtained from a stop of his vehicle. The trial court concluded that, by a preponderance of the evidence, the arresting officer had an objectively reasonable belief that Defendant had violated Me. Rev. Stat. 29-A, which prohibits braking or accelerating that is “unnecessarily made so as to cause a harsh and objectionable noise.” The Supreme Judicial Court affirmed, holding that there was no error in the court’s findings of fact or conclusions of law. View "State v. Violette" on Justia Law

Mainers for Fair Bear Hunting (MFBH) is a Maine ballot question committee that was a proponent of November 2014 Ballot Question 1 concerning bear hunting and trapping. As early as September 2013, the Department of Inland Fisheries and Wildlife used agency resources to communicate with the public in opposition to Question 1. MFBH filed a complaint against the Department alleging that the Department’s campaign activities constituted an ultra vires expenditure of public funds. In November 2014, Maine voters defeated the ballot question. The Department subsequently filed a motion to dismiss MFBH’s complaint on the grounds of mootness and standing. In March 2015, the superior court dismissed the complaint as moot. The Supreme Court affirmed, holding that the case is moot and that no exceptions to the mootness doctrine apply. View "Mainers for Fair Bear Hunting v. Dep’t of Inland Fisheries & Wildlife" on Justia Law

After a jury trial, Defendant was convicted of criminal threatening. Before trial, Defendant filed a motion to suppress statements he had made after police officers stopped his vehicle, took his license and registration, and asked him to wait for a detective to arrive. The suppression court granted the motion in part but denied it as to the statements Defendant made before he was placed in handcuffs and arrested, holding that Defendant was not in custody until he was placed in handcuffs and that after he was handcuffed he did not waive his Miranda rights. Defendant appealed, arguing that the trial court erred by declining to suppress the statements that he made to the detective before his formal arrest. The Supreme Court vacated the judgment of conviction and vacated the suppression order in part, holding that Defendant was in custody when he responded to the detective’s questions and accusations, and because he was in custody when he made incriminating statements without the benefit of Miranda warnings, those statements were improperly admitted at trial. Remanded. View "State v. King" on Justia Law

Defendant entered a conditional guilty plea to operating under the influence. Defendant appealed, arguing that the suppression court erred in denying his motion to suppress evidence obtained from the stop of his vehicle by a game warden. The suppression court found that the warden stopped Defendant’s vehicle after making an “unnecessarily wide” right turn into the approaching lane of another road. The Supreme Court affirmed, holding that the warden’s testimony was sufficient to support the suppression court’s finding that the warden had a reasonable articulable suspicion that Defendant had committed a traffic violation and that the warden’s subjective suspicion was objectively reasonable under the circumstances. View "State v. Simmons" on Justia Law

After a jury trial, Defendant was convicted of robbery. Defendant proceeded to trial without representation after the trial court determined that Defendant had forfeited his right to counsel after threatening to cause serious bodily harm to one of his attorneys in the presence of another attorney, by his deliberate unwillingness to work with those attorneys’ predecessors, and by failing to show that he would work cooperatively with successor counsel. The Supreme Judicial Court affirmed the trial court’s decision to require Defendant to proceed to trial without legal representation, holding (1) in circumstances of egregious misconduct, an accused can forfeit his right to counsel, and in this case, the trial court did not err in concluding that Defendant’s conduct rose to the level that constituted a forfeiture; and (2) in the alternative, the record established that through his egregious misconduct, Defendant waived his right to counsel by implication. View "State v. Nisbet" on Justia Law

After a jury trial, Defendant was convicted of operating under the influence and violating a condition of release. Defendant was sentenced to a term of sevens days in county jail. On appeal, Defendant argued that the trial court erred in denying his motion to suppress and, at trial, in admitting evidence of his blood-alcohol level derived from a sample of his blood that was seized without a search warrant. The Supreme Judicial Court affirmed, holding that the trial court did not err in denying the motion to suppress, as there were exigent circumstances at the time of the blood draw negating the requirement for a search warrant. View "State v. Arndt" on Justia Law

After a jury trial, Defendant was convicted of one count of Class B unlawful sexual contact and two counts of Class C unlawful sexual contact. Defendant appealed, arguing that his conviction on the Class B charge should be vacated because the proof at trial varied from the dates alleged in the indictment and, therefore, his constitutional right to be protected from double jeopardy was implicated. The Supreme Judicial Court affirmed, holding that the variance between the indictment and the evidence presented at trial did not violate Defendant’s right to protection from double jeopardy and did not defeat the conviction for the Class B charge of unlawful sexual contact. View "State v. Lyon" on Justia Law

After a jury trial, Defendant was convicted of one count of gross sexual assault and fifteen counts of unlawful sexual contact. Defendant later filed a petition for post-conviction review, claiming that trial counsel was ineffective by failing to seek a continuance of the sentencing hearing when Defendant was allegedly incompetent and was unable to exercise his right of allocution due to his emotional state. The court denied the petition. The Supreme Judicial Court affirmed, holding that the evidence did not compel the court to find that Defendant was deprived of constitutionally effective assistance when his trial counsel proceeded with, rather than sought to continue, the sentencing hearing despite Defendant’s confused and emotional state. View "Middleton v. State" on Justia Law