Narrative Opinion Summary
The case involves the appeal of defendants convicted of criminal trespass under 17-A M.R.S.A. § 402 after their arrest during a peace demonstration at Bangor International Airport. The defendants challenged the exclusion of evidence, jury instructions, and the sentences imposed. They argued their actions were justified under the 'competing harms' statute, claiming the need to prevent imminent harm from nuclear war. However, the court found their defense inapplicable, as the statute requires a direct link between actions and harm prevention, which the defendants failed to demonstrate. Additionally, the court upheld the exclusion of evidence related to this defense. The defendants also raised issues with jury instructions but had not objected during the trial, limiting appellate review to obvious errors, which were not found. The appellate court affirmed the convictions but vacated the sentences, ruling that the Superior Court improperly considered the defendants' exercise of their right to a jury trial in sentencing, violating due process. Justice Wathen dissented, arguing the sentencing was within statutory limits and should not have been overturned. The case emphasizes the limitations of the 'competing harms' defense and the constitutional protection of the right to a jury trial in sentencing decisions.
Legal Issues Addressed
Criminal Trespass under 17-A M.R.S.A. § 402subscribe to see similar legal issues
Application: Defendants were convicted of criminal trespass for entering Bangor International Airport during a demonstration without authorization.
Reasoning: Defendants Lawrence Dansinger and others appealed their convictions for criminal trespass under 17-A M.R.S.A. § 402, stemming from their arrest during a peace demonstration at the Bangor International Airport on August 5, 1984.
Exclusion of Evidence and Motion in Liminesubscribe to see similar legal issues
Application: The Superior Court's exclusion of certain defense evidence through a motion in limine was upheld, as the evidence was deemed irrelevant to the 'competing harms' defense.
Reasoning: The Superior Court had suggested a motion in limine to exclude certain defense evidence, which the Defendants argued was relevant to their justification based on the 'competing harms' statute and international law principles.
Jury Instructions and Obvious Error Reviewsubscribe to see similar legal issues
Application: Defendants' failure to object to jury instructions before deliberation limited appellate review to obvious errors, which the court found were not present.
Reasoning: The Defendants claimed the court made reversible errors regarding jury instructions but failed to object before the jury deliberated, limiting the appeal review to obvious errors affecting substantial rights.
Justification Defense: Competing Harmssubscribe to see similar legal issues
Application: The court rejected the defendants' justification defense under the 'competing harms' statute, noting that their actions did not meet the statutory requirements of preventing imminent harm.
Reasoning: Defendants argue that their intentional criminal trespass is justified by a 'competing harms' rationale to prevent imminent physical harm ... the statute demands a direct connection between the defendant's actions and a reduction in the threat of harm, which the Defendants failed to establish.
Sentencing and Constitutional Limitssubscribe to see similar legal issues
Application: The appellate court vacated the sentences imposed by the Superior Court due to improper consideration of the defendants' exercise of their right to a jury trial, which violated due process.
Reasoning: The appellate review focuses on the legality of the sentence, constrained by constitutional and statutory limits. It is established that punishing an individual for the exercise of their constitutional right to trial violates due process.
Supremacy of International Treatiessubscribe to see similar legal issues
Application: Defendants' argument that international law justified their actions was dismissed, as international treaties do not influence domestic criminal law defenses.
Reasoning: While international treaties hold supremacy, they pertain to international rights and not domestic legal frameworks.