Justia Constitutional Law Opinion Summaries

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

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

The Supreme Judicial Court affirmed Defendant's conviction for intentional or knowing murder and sentence of forty years' imprisonment, holding that there was no error in the proceedings below.Specifically, the Supreme Judicial Court held that the trial court (1) did not err in determining that Defendant had waived the religious privilege in relation to a communication he made to church leaders; (2) did not err by declining to give Defendant's requested jury instruction that the State was required to prove that he intentionally or knowingly killed the victim and not just intentionally or knowingly killed another human being; (3) did not err when it denied Defendant's motion to continue the sentencing hearing; and (4) misapplied no legal principles and acted within its discretion in sentencing Defendant. View "State v. Gaston" on Justia Law

The Supreme Judicial Court vacated the judgment entered by the superior court denying in part Petitioner's petition for post-conviction review of his conviction on several sexual assault charges, holding that Petitioner was deprived of his right to the effective assistance of trial counsel.After a trial, the jury found Petitioner guilty of one count each of gross sexual assault, unlawful sexual contact, and sexual abuse of a minor. The Supreme Court affirmed. Petitioner subsequently filed a postconviction petition arguing that he had been deprived of his right to the effective assistance of counsel. The Supreme Court granted the petition as to the convictions for unlawful sexual contact and sexual abuse of a minor and vacated Petitioner's convictions on those counts but denied Petitioner's petition as to the conviction for gross sexual assault. The Supreme Judicial Court vacated the judgment and remanded for entry of a judgment granting Petitioner's petition for post-conviction review and vacating the remaining conviction, holding that counsel's performance was deficient and that Petitioner was entitled to post-conviction relief from the remaining portion of the judgment of conviction. View "Hodgdon v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court affirming the Department of Public Safety's denial of Appellant's application for a professional investigator license, holding that Appellant's First Amendment rights were not violated by the application of statutory competency standards to his conduct on social media.The Department denied Appellant's application based on comments and posts that he had made on social media using an account bearing the name of his out-of-state private investigation business concerning a police lieutenant. The Supreme Judicial Court affirmed the circuit court's affirmation of the Department's decision, holding (1) intermediate scrutiny applies to the Department's application of the licensing statutes to Appellant's application; (2) the Department did not err in its findings; and (3) the Department's application of the licensing standards to Appellant did not violate the First Amendment. View "Gray v. Department of Public Safety" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of possession of sexually explicit material, holding that the superior court did not err by denying Defendant's motion to suppress on the grounds that Defendant, despite his diagnosis of Autism Spectrum Disorder (ASD), was capable of voluntary consent.Defendant sought to suppress his statements to police regarding sexually explicit material depicting minors found on his electronic tablet and any evidence of sexually explicit materials depicting minors discovered as a result. The superior court denied Defendant's motion to suppress, concluding that Defendant had the capacity to and did voluntarily speak to the police and consent to the search of his tablet. The Supreme Judicial Court affirmed, holding that Defendant's ASD did not render his statements or the search of his tablet involuntary. View "State v. Glenn" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of domestic violence assault, holding that Defendant was not prejudiced.On appeal, Defendant argued (1) the trial court erred by allowing testimony from Defendant's fifteen-year-old daughter concerning Defendant's parenting practices, and (2) the State committed prosecutorial misconduct by commenting on admissible evidence during its cross-examination of her. The Supreme Judicial Court affirmed, holding (1) because, in her opening statement, Defendant indicated her pursuit of the parental discipline justification found at Me. Rev. Stat. 17-A, 106(1), the court did not err in admitting evidence of Defendant's parenting; and (2) the State committed prosecutorial conduct by eliciting and commenting on evidence that other children had been removed from Defendant's home, but the error was not so prejudicial that it affected the outcome of the proceeding. View "State v. Pratt" on Justia Law

The Supreme Judicial Court affirmed the interlocutory order of the superior court denying Defendant's motion to dismiss on double jeopardy grounds a superseding indictment against him, holding that neither the United States Double Jeopardy Clause nor its counterpart in the Maine Constitution barred the State from retrying Defendant on the superseding indictment.On appeal, Defendant argued that the superior court erred in denying his motion to dismiss because the dismissal of the original indictment against him after the jury was empaneled and sworn barred the State from charging him twice with the same offense. The Supreme Judicial Court clarified the implications of a defective indictment for purposes of the Double Jeopardy Clauses of the state and federal Constitutions and affirmed, holding (1) jeopardy attached in Defendant's trial; but (2) the trial court's dismissal of the indictment was not the equivalent of an acquittal and did not bar retrial. View "State v. Shirey" on Justia Law

In this action brought by Plaintiff, an inmate, the Supreme Judicial Court vacated the portions of the superior court's judgment denying injunctive relief, restoring good-time credit for the period of Plaintiff's nondisciplinary segregation, and entering judgment for Defendants on Plaintiff's 42 U.S.C.S. 1983 claim, holding that restoration of Plaintiff's "good time" was not an available remedy through judicial review of the Department's disciplinary action against Plaintiff and that the Maine Constitution's mandate regarding separation of powers does not preclude an award of injunctive relief on a section 1983 claim against the Department of Corrections.Plaintiff filed a complaint seeking judicial review of a disciplinary decision of the Department and injunction for violations of his civil rights. The superior court vacated the disciplinary decision but concluded that it was prohibited from entering injunctive relief on the section 1983 claim. The court then restored good-time credit for the period of nondisciplinary segregation as a remedy for Plaintiff's Rule 80C claim and entered judgment for Defendants on the section 1983 claim. The Supreme Judicial Court vacated the judgment in part and remanded for the court to determine whether injunctive relief should be awarded, enter judgment in Plaintiff's favor on his section 1983 claim and ordered the restoration of good-time credit for the period of Plaintiff's nondisciplinary segregation as a remedy for the constitutional violations alleged in his section 1983 claim. View "Burr v. Department of Corrections" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of intentional or knowing murder of a deputy sheriff, holding that there was no error, clear or otherwise, in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial court did not abuse its discretion in permitting the State to introduce in-court demonstrations of the possible circumstances of the shooting and in allowing the demonstration to be presented to the jury over Defendant's Rule 403 objection; (2) the trial court did not err in partially denying Defendant's motion to suppress statements he made to detectives after his arrest; and (3) there was no error in the court's sentencing proceedings, and the court did not abuse its discretion in imposing a sentence of life imprisonment. View "State v. Williams" on Justia Law