Justia Constitutional Law Opinion Summaries

Articles Posted in Maine Supreme Judicial Court
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The Supreme Judicial Court affirmed Defendant's conviction of aggravated trafficking of scheduled drugs, holding that the trial court did not err in denying Defendant's motion to suppress, and Defendant's remaining allegations of error were unavailing.Specifically, the Supreme Judicial Court held (1) because law enforcement had probable cause to arrest Defendant, the court did not err in denying Defendant's motion to suppress; (2) the trial court did not err in determining that there was no violation of the court's sequestration order; (3) there was no obvious error in the instructions given to the jury; and (4) there was no illegality in the sentence or in the court's procedure. View "State v. Rosario" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder and his sentence of fifty years in prison, holding that there was no error or abuse of discretion.At issue on appeal was whether the trial court erred in denying Defendant's motion to suppress his statements to law enforcement while walking them through his home. The Supreme Judicial Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant's motion to suppress a video recording of a walk-through of the crime scene, as there was no police misconduct in the interviews and walk-through with Defendant; (2) did not err in denying Defendant's motion for judgment of acquittal; (3) did not commit obvious error in not instructing the jury on concurrent causation; and (4) did not misapply legal principles or abuse its sentencing power in setting the basic sentence. View "State v. Athayde" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered after a jury trial, holding that Defendant was not entitled to relief on her allegations of error.After a trial, a jury found Defendant guilty of operating under the influence and of having a blood-alcohol level of .15 grams or more per 210 liters of breath at the time of the offense. The Supreme Judicial Court affirmed, holding that the trial court (1) did not err in denying Defendant's challenge for cause to a prospective juror based on implied bias; and (2) did not violate Defendant's constitutional rights by factoring into her sentence the court's view that her testimony was untruthful without making perjury findings. View "State v. Hemminger" on Justia Law

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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