State of Maine v. Carol Ann Murphy
2017 ME 165
| Me. | 2017Background
- Carol Ann Murphy had two prior convictions for cruelty to animals and a court-imposed lifetime prohibition on owning or possessing animals following the 2010 conviction.
- In 2014 police executed a search warrant at Murphy’s home and seized multiple animals (dogs, cats, chinchillas, rabbits, and a potbellied pig); the State charged her with contempt for violating the prohibition.
- Murphy filed numerous pro se filings asserting fanciful jurisdictional and authority defects (challenging the court, judge, and prosecutor appointments) and frequently failed to cooperate with proceedings.
- After procedural delays and appointment of standby counsel, Murphy elected self-representation at a jury trial; the State presented uncontroverted evidence that she possessed animals in violation of the prior order.
- The jury found Murphy in contempt; the Superior Court sentenced her to 364 days imprisonment and the court later corrected the judgment to strike an incorrect classification of the contempt as a Class D crime.
Issues
| Issue | Plaintiff's Argument (Murphy) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Court jurisdiction to hear contempt | Superior Court lacked jurisdiction; prior proceedings were void | Court properly had jurisdiction under Maine law | Court had jurisdiction; Pelletier controls; challenge rejected |
| Validity of judge and prosecutor appointments | Appointments were defective, so proceedings were void | Appointments were valid under state constitution/statutes | Appointments not infirm; challenge rejected |
| Validity of prior convictions/order | Prior cruelty convictions and resulting prohibition are void | Prior convictions and the prohibition are valid (on the record) | Prior convictions and prohibition are valid; challenge rejected |
| Due process / fair trial claims | Proceedings violated constitutional rights (denied counsel, unfair process) | Court provided appointed counsel, warnings, standby counsel, notice, and opportunity to be heard | Murphy received required due process and a fair trial |
| Classification of contempt adjudication | (not directly contested) | Judgment classified contempt as Class D | Court sua sponte corrected judgment to remove Class D classification; conviction and 364-day sentence affirmed |
Key Cases Cited
- State v. Pelletier, 125 A.3d 354 (Me. 2015) (addresses Superior Court jurisdiction issues)
- State v. Murphy, 10 A.3d 697 (Me. 2010) (prior appeal affirming Murphy's earlier conviction and sentence)
- State v. Hill, 86 A.3d 628 (Me. 2014) (standards and warnings for defendants choosing self-representation)
- State v. St. Onge, 21 A.3d 1028 (Me. 2011) (contempt adjudication stands alone; classification on judgment should be corrected)