Summary
The defendants appealed their convictions for criminal trespass arising from a nuclear arms protest, challenging the exclusion of justification evidence via a motion in limine, alleged errors in jury instructions, and the imposition of fines. The Supreme Judicial Court of Maine affirmed the convictions, finding no abuse of discretion in excluding the evidence or error in the jury instructions. However, the court vacated the sentences and remanded for re-sentencing because the trial judge explicitly stated the fines were intended to recoup costs associated with the defendants' exercise of their constitutional right to a jury trial.
Topics
Practice areas
Questions Presented
- Whether the trial court abused its discretion in granting the motion in limine to exclude the defendants' competing‑harms and international‑law evidence.
- Whether the jury instructions on criminal trespass contained an obvious error affecting substantial rights.
- Whether the sentences imposed violated the defendants' constitutional right to a jury trial and therefore must be vacated.
Holdings
- The Supreme Judicial Court affirmed the trial court's decision to exclude the evidence, finding no abuse of discretion.
- The instructions were not an obvious error; the conviction was affirmed.
- The sentences were unconstitutional and are vacated; the case is remanded for resentencing.
Key quotations
“We conclude, then, that these sentences were an unconstitutional punishment of the Defendants' legal exercise of their right to a trial by jury.” (690)
“The Defendants contend that the Superior Court committed reversible error in (1) suggesting that the State move for an order in limine to exclude certain evidence the Defendants wished to adduce at the jury trial; (2) ruling on the motion in a manner erroneous as a matter of law; (3) instructing the jury in a manner that was erroneous and incomplete; and (4) imposing sentences that were improper because the sentencing justice stated that these sentences were based in part on the fact that the Defendants claimed their constitutional right to a jury trial.” (686)
Factual background
On August 5, 1984 the defendants were arrested for criminal trespass after a peace demonstration at the Bangor International Airport. They were charged under 17‑A M.R.S.A. § 402, a Class E crime, and each pleaded not guilty. At trial they sought to introduce a "competing harms" defense and evidence of international law, which the trial court excluded via a motion in limine.
Procedural history
The defendants were convicted of criminal trespass in the Superior Court and sentenced to fines. They appealed alleging reversible error in the trial court's motion in limine, jury instructions, and sentencing.
Remand instructions
Remand for sentencing consistent with the opinion herein.