Justia Constitutional Law Opinion Summaries

The Supreme Judicial Court vacated the portion of the superior court's judgment dismissing the declaratory judgment count of Appellants' complaint seeking a declaration that a certain citizen initiative failed to meet the constitutional requirements for inclusion on the November 2020 ballot, holding that the initiative was unconstitutional and could not be submitted to the electors for popular vote.At issue was a citizen initiative that proposed a resolve that would reverse an order of the Maine Public Utilities Commission granting Central Maine Power Company's (CMP) request for a certificate of public convenience and necessity for a 145-mile transmission line. Avangrid Networks, Inc., the company that owned CMP as a subsidiary, filed a complaint leading to the present litigation, seeking a declaratory judgment and injunctive relief. The district court dismissed the complaint, concluding that the initiative's constitutionality was not subject to judicial review before the election. The Supreme Judicial Court vacated the judgment, holding that the initiative failed to meet the constitutional requirements for inclusion on the ballot because it exceeded the scope of the legislative powers conferred by article IV, part 3, section 18 of the Maine Constitution. View "Avangrid Networks, Inc. v. Secretary of State" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant for failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999), Me. Rev. Stat. 34-A, 11227(2), holding that, due to inadequate representation by Defendant's trial counsel, the court committed obvious error by not addressing the constitutionality of SORNA of 1999, as retroactively applied to Defendant.In 1990, Defendant was convicted of four counts of unlawful sexual contact, and in 1992, he was convicted of gross sexual assault. Neither offense required Defendant to register as a sex offender. After the Legislature enacted SORNA of 1999, Defendant 's two convictions became subject to SORNA of 1999. In 2018, Defendant was found guilty of failure to comply with a duty under SORNA of 1999. On appeal, Defendant argued that the retroactive application of SORNA of 1999 to require him to register for life violated the state and federal constitutional prohibitions against ex post facto laws. The Supreme Judicial Court agreed, holding that it could not be said beyond a reasonable doubt that the retroactive application of SORNA of 1999 to Defendant's 1990 and 1992 convictions did not affect his substantial rights by virtue of a punitive alteration of his original sentences. View "State v. Proctor" on Justia Law

The Supreme Judicial Court affirmed the order of the district court committing M. to involuntary hospitalization for up to 120 days, holding that the evidence was sufficient to support the court's decision to order M.'s involuntary hospitalization.The district court authorized M.'s hospitalization for up to 120 days, and the superior court affirmed. On appeal, M. argued that she was denied due process and a fair appeal because there was no verbatim transcript of her commitment hearing and that the record contained insufficient evidence to support the court's findings. The Supreme Judicial Court affirmed, holding (1) the opportunities afforded to M. to supplement the incomplete transcript were sufficient to satisfy due process; and (2) there was sufficient evidence to support the district court's decision. View "In re Involuntary Commitment of M." on Justia Law

The Supreme Judicial Court vacated the trial court's judgment on remand after Defendant successfully argued that his two convictions of felony murder and robbery violated his right to be free from double jeopardy, holding that the trial court erred by allowing the State to dismiss the robbery count on remand rather than merging it into the felony murder count.On remand, instead of the trial court merging the counts, the robbery count was dismissed by the State. The Supreme Judicial Court vacated the judgment, holding (1) when a trial results in multiple verdicts for the same offense, the appropriate procedure to prevent a double jeopardy violation is to merge, not dismiss, the duplicative counts; and (2) the trial court's failure to hold a new sentencing hearing on remand and conduct a new sentencing analysis pursuant to Me. Rev. Stat. 17-A, 1602 deprived Defendant of a substantial right. View "State v. Armstrong" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court after a jury found Defendant guilty of burglary and theft by unauthorized taking, holding that the trial court did not commit reversible error.On appeal, Defendant argued that the trial court erred in denying his motion to suppress portions of a surveillance video recording because other portions of the recording were not preserved and that the court committed obvious error by failing to intervene after several allegedly improper comments made by the prosecutor during closing argument. The Supreme Judicial Court affirmed, holding (1) the trial court's finding that the State did not act in bad faith when it failed to preserve the remainder of the recording did not constitute clear error, and therefore, the court did not err when it denied Defendant's motion to suppress; and (2) the majority of the prosecutor's statements challenged on appeal did not rise to the level of misconduct, and as to the remaining statement, the court's instructions clarified any misimpression that the prosecutor's comments may have created. View "State v. Chan" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court terminating Defendant's deferred disposition and imposing sentence following his earlier guilty plea to trafficking in prison contraband, holding that the court did not err in admitting evidence at the termination hearing that had been suppressed in a separate criminal case.Defendant pleaded guilty to trafficking in prison contraband, and the court deferred disposition on that count. Defendant was subsequently indicted on new criminal charges. The court granted Defendant's motion to suppress evidence resulting from a police officer's search of his pocket on the basis that the search was unconstitutional. The State then dismissed the charges. In the first case, the State moved to terminate Defendant's deferred disposition based on his alleged new criminal conduct. Defendant sought an order continuing suppression of the evidence. The court denied Defendant's motion. The court then found that Defendant had violated the deferred disposition agreement and imposed sentence. The Supreme Judicial Court affirmed, holding that because the "sole purpose" of the exclusionary rule was satisfied by the exclusion of the evidence derived from the unlawful search in the dismissed criminal case, the trial court did not err in ruling that the suppressed evidence could be considered in the deferred disposition termination proceeding. View "State v. Hourdeh" on Justia Law

In this appeal from Defendant's conviction for eleven counts of gross sexual misconduct, the Supreme Judicial Court vacated the judgment of conviction on one count, vacated the dismissal of other counts and remanded for entry of a judgment of acquittal on those counts, and affirmed in all other respects, holding that Defendant's convictions on both Counts 5 and 30 violated his double jeopardy protections and that the court erred in allowing the State to dismiss Counts 27, 28, and 29 during trial without Defendant's consent.The indictment charged Defendant with fifteen counts (Counts 1-13, 30-31) of gross sexual misconduct against the victim and sixteen counts (Counts 14-29) of gross sexual misconduct against a second alleged victim. During trial, the court granted Defendant's motion for a judgment of acquittal on Counts 10-13, and the State dismissed Counts 27-29. Defendant was found guilty of Counts 1-9 and 30-31 and not guilty on the remaining counts. The court entered judgment in accordance with the verdict. The Supreme Judicial Court held that the trial court erred in failing to rule that the Double Jeopardy Clause barred convictions on both Counts 5 and 30 and allowing the State to dismiss Counts 27, 28, and 29 rather than entering a judgment of acquittal on those counts. View "State v. Paquin" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court as a result of a jury verdict finding Defendant guilty of two counts of manslaughter, two counts of causing a death while operating under the influence, and related charges, holding that the court did not err when it denied Defendant's motion to suppress the results of a warrantless blood draw taken at the scene of a fatal motor vehicle accident.Me. Rev. Stat. 29-A, 2522(2) directs law enforcement officers to test the blood of all drivers involved in a fatal, or likely fatal, motor vehicle accident without any requirement of probable cause before the blood draw. Defendant argued on appeal that the statute is unconstitutional on its face. The Supreme Judicial Court agreed but nonetheless affirmed the trial court's denial of Defendant's motion to suppress, holding (1) Me. Rev. Stat. 29-A, 2522(2) violates the Fourth Amendment because it does not require that law enforcement have consent or probable cause to believe that a driver is impaired before drawing a person's blood; but (2) the trial court correctly denied Defendant's motion to suppress because the "good faith" exception to the exclusionary rule applied to the search. View "State v. Weddle" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court affirming the second decision of the Scarborough Board of Assessment Review granting Taxpayers 14.74 percent abatements to their land values, holding that the Board's original abatements reviewed by the superior court after this Court's remand satisfied constitutional requirements.In previous opinions, the Supreme Judicial Court concluded that the Board had erred in denying Taxpayers' abatement requests to their land values. On remand, the Board granted Taxpayers eight percent abatements to their land values. The superior court vacated the Board's decision, concluding that the Board's abatement formulate was unreasonable. On remand, the Board determined that Taxpayers were entitled to 14.74 percent abatements. The superior court affirmed. The Supreme Judicial Court vacated the superior court's judgment affirming the Board's second decision granting 14.74 percent abatements and remanded with directions to affirm the Board's first decision, holding that the Board's original decision was not outside the reasonable range of discretion allowed the Board under this Court's precedents. View "Bolton v. Town of Scarborough" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of intentional or knowing murder, holding that the trial court did not err in denying Defendant's motion to suppress evidence of his cell site location information (CSLI).On appeal, Defendant argued that the judge who issued the warrant permitting officers to obtain his CLSI erred in determining that there was probable cause supporting the warrant's issuance. The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence of his CSLI, holding that the information in the affidavit was sufficient to support the judge's determination that there was probable cause to believe that Defendant was involved in the two homicides and that his CSLI would contain or constitute evidence relevant to the crime. View "State v. Marble" on Justia Law