Justia Constitutional Law Opinion Summaries

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

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of aggravated trafficking of scheduled drugs and one count of unlawful trafficking in scheduled drugs and finding that $1,500 was subject to criminal forfeiture, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) Defendant's claim that his right to a speedy trial was violation under the Maine Constitution failed because he did not adequately assert his right, and his speedy trial claim under the United States Constitution failed under obvious error review; (2) Defendant's claim under the Maine Constitution that evidence obtained pursuant to the execution of a search warrant was inadmissible was unpreserved, and his claim under the United States Constitution that the warrants were not supported by probable cause failed; and (3) Defendant's last argument on appeal was unavailing. View "State v. Norris" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction on charges of domestic violence aggravated assault and domestic violence assault and the trial court's finding of guilty on a charge of violating a condition of release, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the trial court violated his constitutional right to a representative jury by using the absolute disparity test to determine the racial makeup of the jury venire. The Supreme Judicial Court disagreed and affirmed, holding that the trial court (1) appropriately determined the 1.01% absolute disparity in Defendant's jury venire was insufficient to show underrepresentation; and (2) did not abuse its discretion in denying Defendant's motion to subpoena the grand jurors. View "State v. Footman" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful trafficking in scheduled drugs and falsifying physical evidence, entered after a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized as the result of what Defendant argued was an unlawful arrest; (2) there was no obvious error in the admission of lay opinion testimony by law enforcement officers on certain matters; (3) the record evidence was sufficient to justify the trial court's giving a permissible-inference instruction; and (4) there was no error or abuse of discretion in the denial of Defendant's motion for new trial and for judgment of acquittal. View "State v. Abdullahi" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of gross sexual assault and two counts of unlawful sexual contact, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the district court did not abuse its discretion in denying Defendant's motion for a continuance; (2) there was no constitutional error in the trial court's ruling requiring that participants in Defendant's trial be masked; (3) there was no prosecutorial error in either the State's opening or closing argument or in the State's rebuttal argument; and (4) Defendant's claims of evidentiary error were unavailing. View "State v. Hunt" on Justia Law

The Supreme Judicial Court vacated the judgment of the post-conviction review (PCR) court denying Appellant's PCR petitions, holding that the PCR court misconstrued aspects of the relevant law.In his speedy trial petitions, Defendant argued that his rights to a speedy trial had been violated and that his trial counsel provided ineffective assistance by failing to raise his speedy trial claims. The PCR court denied the petition. Thereafter, Defendant sought a certificate of probable cause. The Supreme Judicial Court vacated the judgment below, holding (1) the PCR court utilized a faulty analysis in concluding that there was no merit to Defendant's speedy trial claim; and (2) because the PCR court did not analyze counsel's strategy in failing to assert Defendant's right to a speedy trial the case must be remanded. View "Winchester v. State" on Justia Law