State of Maine v. Jacob L.

2017 ME 112, 163 A.3d 827, 2017 WL 2438528, 2017 Me. LEXIS 122
CourtSupreme Judicial Court of Maine
DecidedJune 6, 2017
StatusPublished

This text of 2017 ME 112 (State of Maine v. Jacob L.) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Maine v. Jacob L., 2017 ME 112, 163 A.3d 827, 2017 WL 2438528, 2017 Me. LEXIS 122 (Me. 2017).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2017 ME 112 Docket: Pen-16-395 Argued: April 13, 2017 Decided: June 6, 2017

Panel: SAUFLEY, C.J., and ALEXANDER, MEAD, GORMAN, JABAR, HJELM, and HUMPHREY, JJ.

STATE OF MAINE

v.

JACOB L.

HJELM, J.

[¶1] Jacob L. appeals from an order denying his motion for return of

property, see M.R.U. Crim. P. 41(j),1 entered after a hearing in the Juvenile

Court2 (Bangor, Lucy, J.), following entry of a judgment adjudicating him of the

juvenile crime of aggravated assault (Class B), 17-A M.R.S. § 208(1)(B) (2016);

see also 15 M.R.S. § 3103(1) (2016) (defining “juvenile crime”). Jacob argues

that the court applied an incorrect legal standard when it determined that the

State was entitled to retain possession of cash that had been seized from him

as evidence against a co-defendant, and that the court’s findings were not

1 The Maine Rules of Unified Criminal Procedure apply to juvenile crime proceedings. See 15 M.R.S. § 3309 (2016); M.R.U. Crim. P. 1(b)(3).

2 When exercising its exclusive original jurisdiction over juvenile petitions, the District Court is

referred to as the Juvenile Court. See 15 M.R.S. § 3101(1), 2(A) (2016). 2

supported by sufficient evidence. Because the court has not yet issued an

order determining who owns or is otherwise entitled to possession of the

cash, we dismiss this appeal as interlocutory.

I. BACKGROUND

[¶2] The central facts are undisputed, either as established in the

record or as the parties have framed their arguments.

[¶3] In the early morning hours of March 25, 2016, a Bangor police

officer responded to the scene of a reported robbery and assault. The victim

told the officer that two males had beaten him with a two-by-four and had

taken about $800 in cash from his pocket, along with some other items.

[¶4] Based on physical descriptions provided by the victim and his

girlfriend, other officers detained two suspects, including Jacob, at a nearby

convenience store. The girlfriend identified the suspects as the attackers, and

the officers then arrested Jacob on several outstanding warrants. They also

arrested the other suspect. One of the arresting officers searched Jacob for

weapons and found a large roll of money in his pocket. At the police station

the officer counted the money and found that there was $1,310, which was

retained as evidence. The victim later told the police that the amount of stolen

cash totaled $1,300 rather than the $800 he had reported initially. 3

[¶5] On March 31, 2016, Jacob was charged by petition with the

juvenile crimes of robbery (Class A), 17-A M.R.S. § 651(1)(D) (2016);

aggravated assault (Class B), 17-A M.R.S. § 208(1)(B); and theft by

unauthorized taking or transfer (Class D), 17-A M.R.S. § 353(1)(B)(5) (2016).

At a hearing on April 26, Jacob entered an admission to the juvenile crime of

aggravated assault, and the State dismissed the remaining charges. The court

committed Jacob to a juvenile detention facility for an indeterminate period to

age twenty. See 15 M.R.S. §§ 3310(5), 3314(1)(F) (2016).

[¶6] Pursuant to M.R.U. Crim. P. 41(j),3 Jacob filed a post-judgment

motion for return of property—namely, the cash seized from him when he

was arrested—asserting that the State’s continued retention of the cash was

illegal. The State opposed the motion, and a hearing was held on August 2,

2016. The evidence presented at the hearing consisted only of the police

reports that had been filed in support of the juvenile petition.

3 Rule 41(j) of the Maine Rules of Unified Criminal Procedure states,

A person aggrieved by an unlawful seizure of property may file a motion in the Unified Criminal Docket for the return of the property on the ground that it was illegally seized. The court shall receive evidence on any issue of fact necessary to the decision of the motion. If the motion is granted the court shall order that the property be restored unless otherwise subject to lawful detention. The motion may be joined with a motion to suppress evidence. 4

[¶7] At the conclusion of the hearing, the court denied Jacob’s motion.

The court found that the State was entitled to retain the cash because there

was “probable cause to believe that [Jacob and his co-defendant] beat up [the

victim] and took his money[,] [a]nd that the money that the State [was]

holding represent[ed] some or all of what was taken from [the victim] after

[Jacob] hit him with a two-by-four.” The court further explained that charges

were still pending against Jacob’s co-defendant and that evidence in his trial

would “further inform this issue.”

[¶8] After the court announced its decision, Jacob asked whether he

would be permitted to file a renewed motion for return of property after the

case against the co-defendant was concluded. The court responded that it

would not give an advisory opinion about “whatever may or may not happen

in the future,” and restated its determination that the State was entitled to

retain the cash. The court further stated, “There may be other recourse

through civil process . . . , but . . . as it stands now there’s nothing else for me to

do on this case.”

[¶9] Jacob timely appealed. At oral argument, both parties told us that

after the court issued its order denying Jacob’s motion, the case against the

co-defendant was fully resolved and is no longer pending. The State also 5

acknowledged that given this development, the cash seized from Jacob has no

remaining evidentiary value.

II. DISCUSSION

[¶10] We must address, as a threshold issue, whether we have

jurisdiction to consider an appeal from an order denying a motion for return

of property in a juvenile crime proceeding. See M.R. App. P. 4(d) (“Whenever

it appears by suggestion of the parties or otherwise that the Law Court lacks

jurisdiction of the subject matter, the Law Court shall dismiss the appeal.”).

[¶11] As the parties acknowledge, the types of orders that a juvenile

may appeal are statutorily enumerated as orders of adjudication, disposition,

and detention. See 15 M.R.S. § 3402(1) (2016). The order denying Jacob’s

Rule 41(j) motion is none of these.4 See 15 M.R.S. § 3003(1), (4-B), (5) (2016)

(defining “[a]djudicatory hearing,” “[d]ispositional hearing,” and

“[d]etention”). If we have appellate jurisdiction over this matter, it must

therefore arise from a different source.

4 Contrary to Jacob’s argument, the order denying his Rule 41(j) motion is not a de facto order of

restitution, which would be appealable pursuant to 15 M.R.S. § 3402(1)(B) (2016), because neither the dispositional order nor the order on Jacob’s Rule 41(j) motion directs that the cash be paid over to the victim. See 15 M.R.S. § 3314(1)(E) (2016) (stating that, as one of the dispositional alternatives available in a juvenile case, “[t]he court may require the juvenile to make restitution for any damage to the victim or other authorized claimant as compensation for economic loss”). Rather, the court simply determined that the State was entitled to hold the cash temporarily while the prosecution against Jacob’s co-defendant was pending. 6

[¶12] Adult criminal defendants are entitled to appeal from an adverse

ruling on a Rule 41(j) motion. See State v. Miller, 645 A.2d 1140, 1141

(Me. 1994);5 see also 15 M.R.S.

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Cite This Page — Counsel Stack

Bluebook (online)
2017 ME 112, 163 A.3d 827, 2017 WL 2438528, 2017 Me. LEXIS 122, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-jacob-l-me-2017.