Justia Constitutional Law Opinion SummariesArticles Posted in Maine Supreme Judicial Court
State v. O’Donnell
The Supreme Judicial Court affirmed Defendant's convictions for burglary, stealing drugs, and violation of a condition of release, holding that the trial court did not err when it denied Defendant's motion to suppress al evidence obtained as a result of the State's acquisition of Defendant's cell phone's location information (CSLI). Specifically, the Supreme Court held (1) because Defendant lacked standing to challenge evidence obtained as a result of the acquisition of a coperpetrator's CLSI, which was the same evidence Defendant sought to exclude based on the acquisition of his own CSLI, this Court need not decide whether the acquisition of Defendant's CSLI was a search under the Fourth Amendment; (2) whether the State violated Defendant's rights under Maine's Electronic Device Location information Act, 16 Me. Rev. Stat. 647 to 650-B, was irrelevant to whether the court erred in denying Defendant's motion to suppress; and (3) the entry into and search of Defendant's residence were lawful. View "State v. O'Donnell" on Justia Law
In re Child of Dawn B.
The Supreme Judicial Court affirmed the judgment of the district court terminating the parental rights of Mother and Father to their child, holding that there was no error in the proceedings below. On appeal, Mother argued that the district court erred in denying her motion for relief from the termination judgment, in which she alleged that she received ineffective assistance of counsel. Father argued that there was insufficient evidence to support the termination of his parental rights. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion by denying Mother's motion for relief from the termination of her parental rights; and (2) there was sufficient evidence in the record to support the court's termination of Father's parental rights. View "In re Child of Dawn B." on Justia Law
State v. Townes
The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of aggravated assault and violating a condition of release, holding that the sanctions imposed on the State were sufficient to remedy the prejudice caused by discovery violations and that there were no other errors in the proceedings below. Specifically, the Court held (1) the court did not abuse its discretion to impose sanctions for the State's discovery violations; and (2) Defendant was not deprived of his Sixth Amendment right to an impartial jury that represented a fair cross section of Defendant's community, and accordingly, the trial court did not err in denying Defendant's motion for a new jury. View "State v. Townes" on Justia Law
Petgrave v. State
The Supreme Judicial Court affirmed the judgment of the trial court summarily dismissing Appellant's petition for post-conviction review alleging ineffective assistance of counsel in his probation revocation matter but that Appellant may file a motion for a new probation revocation hearing in the trial court within thirty-five days of the issuance of this mandate. The trial court concluded that Appellant's remedy for any claim of error arising from the revocation was to seek a discretionary appeal, as Appellant had already done. The Supreme Judicial Court held (1) in a probation revocation hearing, a defendant has a right to the effective assistance of counsel; (2) Appellant's motion was properly dismissed, but Appellant was deprived of an opportunity to obtain meaningful review on his claim; and (3) a defendant who seeks to raise a claim of ineffective assistance of counsel after a probation revocation hearing may do so by filing a motion under Rule 33 of the Maine Rules of Unified Criminal Procedure for a new trial, which must be filed thirty-five days after the entry of judgment, and the judge who issued the revocation judgment will, if the defendant has made out a prima facie claim of ineffective assistance, will hold an evidentiary hearing or dismiss the motion. View "Petgrave v. State" on Justia Law
In re Child of Shayla S.
The Supreme Judicial Court affirmed the judgment of the district court terminating Mother's parental rights to her child pursuant to Me. Rev. Stat. 22, 4055(1)(B)(2)(a), (b)(i)-(ii), (iv), holding that the standard of proof in termination of parental rights cases is constitutionally adequate. On appeal, Mother argued that parental unfitness be proved beyond a reasonable doubt and that the statutory standard burden of proof of clear and convincing evidence was constitutionally insufficient. The Supreme Judicial Court disagreed, holding (1) there is no reason to overturn precedent holding that the standard of proof of clear and convincing evidence is constitutionally sufficient in termination of parental rights cases; and (2) the court acted within its discretion in terminating Mother's parental rights. View "In re Child of Shayla S." on Justia Law
State v. Ayotte
The Supreme Judicial Court affirmed Defendant's conviction of operating under the influence, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained from a blood draw and that the court's jury instructions were sufficient and appropriate. Prior to trial court, Defendant filed a motion to suppress evidence from the blood draw and the corresponding blood-alcohol test result, arguing that the evidence was obtained without valid consent. The trial court denied the motion. After closing arguments, Defendant requested a curative instruction to remedy the State's alleged misstatement of the evidence in its closing argument. The court declined to give such an instruction. The jury subsequently found Defendant guilty of operating under the influence. The Supreme Judicial Court affirmed, holding (1) Defendant had the capacity to give knowing consent to the blood draw, and his consent was voluntary; and (2) the prosecutor's closing statements to the jury did not misstate the evidence, demonstrate bad faith, or create any prejudice. View "State v. Ayotte" on Justia Law
State v. Bennett-Roberson
The Supreme Judicial Court vacated the order of the trial court suppressing evidence obtained during a traffic stop, holding that the motion court erred in restricting its legal analysis to certain evidence. The evidence suppressed in this case was obtained after a Maine State Police trooper stopped and ordered Defendant out of the motor vehicle she was driving so that he could administer field sobriety tests to her. The trial court concluded that the vehicle stop was valid but the subsequently investigatory seizure was not. The Supreme Judicial Court vacated the suppression order, holding that the motion court erred in restricting its analysis to evidence of the events and circumstances occurring at and prior to the moment that the trooper realized that the driver was not the person who was the subject to the complaint that led to the traffic stop. The Court then remanded the case for a determination as to whether the trooper's subsequent actions were reasonably related in scope to the purpose of the initial stop. View "State v. Bennett-Roberson" on Justia Law
Ford v. State
The Supreme Judicial Court vacated the judgment of the superior court denying in part and granting in part Appellant's petition for post-conviction relief as to his felony convictions, holding that the court erred by denying Appellant's petition despite its determination that Appellant had proved ineffective assistance of counsel for Appellant's misdemeanor charge. Appellant was convicted of both felony and misdemeanor counts. Appellant later filed a petition for post-conviction review, alleging ineffective assistance of counsel. The superior court found that Appellant had been denied his right to effective assistance of counsel by counsel's refusal to discuss Appellant's right to testify but concluded that trial counsel's actions prejudiced Appellant only with regard to Appellant's conviction for misdemeanor theft by unauthorized taking. The Supreme Judicial Court vacated the court's judgment and remanded the case, holding that, as a result of counsel's deficient performance, Appellant was prejudiced in his attempt to defend all charges brought against him, entitling him to post-conviction relief from his convictions on all counts. View "Ford v. State" on Justia Law
State v. Cunneen
The Supreme Judicial Court affirmed Defendant's drug-related convictions, holding that the trial court did not err by denying Defendant's motion to suppress evidence obtained as the result of a roadside interaction with a police officer and that any potential challenge to the sentence imposed was not cognizable on direct appeal. Defendant was convicted of unlawful possession of scheduled drugs, unlawful possession of scheduled drugs, and refusing to submit to arrest or detention. On appeal, Defendant argued that his roadside encounter with the officer rose to the level of a detention and was not supported by reasonable articulable suspicion. The Supreme Judicial Court affirmed, holding (1) the trial court correctly found that the officer's conduct and interaction with Defendant did not rise to the level of a Fourth Amendment seizure; and (2) Defendant's challenge to his sentence was not cognizable on this direct appeal. View "State v. Cunneen" on Justia Law
In re Adoption of Riahleigh M.
The Supreme Judicial Court affirmed two separate judgments of the probate court granting the petitions of half-sisters’ maternal grandmother to terminate the fathers’ parental rights as part of the proceeding through which the grandmother sought to adopt the children, holding that the fathers were not deprived of due process and equal protection of the law when the court denied the fathers’ motions for an order requiring the provision of rehabilitation and reunification services. The judicial termination proceedings in these consolidated cases did not involve the Department of Health and Human Services. The fathers argued that they were constitutionally entitled to the services that are ordinarily provided in a title 22 child protection action after a court has found abuse or neglect or has placed a child in foster care under the supervision of the Department. The Supreme Court disagreed, holding that the probate court (1) did not violate the fathers’ constitutional rights by denying the fathers’ motions for orders of rehabilitation and reunification services; and (2) did not err in determining that each father’s parental rights should be terminated. View "In re Adoption of Riahleigh M." on Justia Law