Justia Constitutional Law Opinion Summaries

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

The Supreme Judicial Court vacated in part the order of the superior court granting Defendant's motion to suppress evidence obtained pursuant to a search warrant for Defendant's cell phone account data and a search warrant for a codefendant's cell phone data, holding that there was no illegality in the search of Defendant's data and that Defendant lacked standing to challenge the search of the codefendant's data.On appeal, the State argued that Defendant lacked standing to challenge the warrant issued to search the codefendant's account data and that the superior court erred by determining that neither search warrant was supported by probable cause. The Supreme Judicial Court vacated the order to the extent that it suppressed the evidence obtained through the two warrants, holding (1) the affidavit for the warrant to search Defendant's account data was supported by probable cause; and (2) given that Defendant failed to assert any reasonable expectation of privacy in the codefendant's account data, Defendant lacked standing to challenge the warrant to search the codefendant's data. View "State v. Warner" on Justia Law

The Supreme Judicial Court vacated the judgment entered by the trial court convicting Defendant of unlawful sexual touching and assault, holding that the court erred in allowing the State to introduce improper character evidence and that the prejudice suffered as a result of that error, when considered cumulatively with the effect of an instance of prosecutorial misconduct, deprived Defendant of a fair trial.Although the issue was not preserved at trial or raised on appeal, the Supreme Judicial Court examined the State's cross-examination of Defendant to determine whether prosecutorial misconduct occurred. The Supreme Judicial Court remanded the case for a new trial, holding (1) on the record, prosecutorial misconduct plainly occurred, and the misconduct affected Defendant's substantial rights; (2) the introduction into evidence of federal probation violations was error and highly prejudicial to Defendant; and (3) the cumulative effect of the trial errors deprived Defendant of a fair trial. View "State v. Robbins" on Justia Law

The Supreme Judicial Court affirmed the judgment of the unified criminal docket convicting Defendant of unlawful sexual contact, holding that the trial court did not err when it admitted in evidence as past recollection recorded a video recording in which the victim described Defendant's assaults of her.The video recording was of a forensic interview conducted of the victim shortly after the crime occurred. On appeal, Defendant argued that the court erred in admitting the video in evidence because the State had not established the proper foundation required by the exception to the hearsay rule and because the admission of the video violated his constitutional right to confront the witness. The Supreme Judicial Court disagreed, holding (1) the court did not err by determining that the State had satisfied the foundational elements of the recorded recollection exception to the hearsay rule; and (2) the court did not violate Defendant's constitutional right to confrontation by admitting the evidence because Defendant was provided the opportunity to cross-examine the victim about her out-of-court statements. View "State v. Adams" on Justia Law

The Supreme Judicial Court Defendant's conviction of multiple sex crimes, holding that the trial court did not err in the jury selection process when it denied Defendant's motion to strike one of the jurors for cause and when it denied Defendant's motion to strike the entire venire after one prospective juror left the courtroom in an agitated state.At the beginning of jury selection, one prospective juror abruptly left the room when the charges against Defendant were being described. The court asked the remaining pool of jurors if there was anyone who would have difficulty being fair and impartial going forward, and thirty-four potential jurors answered in the affirmative. Defendant filed a motion to strike the entire jury venire. The court denied the motion, instead striking the thirty-four potential jurors. Defendant later moved to strike one juror on the ground that he had been equivocal about his ability to remain fair and impartial. The Supreme Judicial Court denied the motion. The Supreme Judicial Court affirmed, holding that the circumstances of this case did not present an extraordinary situation in which prejudice may be presumed or bias implied and that the court did not err in determining that the individual juror's ability to be fair and impartial was not affected. View "State v. Carey" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court acquitting Defendant of murder but finding him guilty of felony murder and robbery in connection with a drug-related homicide, holding that Defendant's conviction for both felony murder and the underlying felony of robbery violated the constitutional protection from double jeopardy.Specifically, the Court held (1) the trial court did not err, while exercising its gatekeeping function, by declining to admit certain hearsay statements because the admission of those statements would have run contrary to the truth-seeking function of Me. R. Evid. 804(b)(3); and (2) although Defendant did not raise the double jeopardy issue in the trial court, the State acknowledged that Defendant's convictions for both robbery and felony murder violated the double jeopardy clauses of the state and federal constitutions, and therefore, the case must be remanded for further post-trial proceedings to eliminate the double jeopardy effect arising from the two charges. View "State v. Armstrong" on Justia Law