State v. Murphy, 10 A.3d 697

Murphy was convicted by jury of assault on an officer, refusing to submit to arrest, criminal use of an electronic weapon, and two cruelty-to-animals counts stemming from an October 14, 2009 incident.
Officer encountered Murphy at her residence with an outstanding arrest warrant; Murphy allowed him in, then attacked him with a Taser during a subsequent exit from the home.
A later search of the property revealed numerous animals in violation of a lifetime ban; several animals were in poor condition, leading to cruelty-to-animals charges.
Murphy, appearing pro se, repeatedly challenged the court’s authority, sought removals to federal courts, and declined to cooperate with a competency examination; standby counsel assisted as needed.
The trial court permitted Murphy to represent herself with standby counsel, ordered a competency exam which found Murphy competent, and the trial proceeded with Murphy absent from the courtroom as disruptions continued.
After a full trial, Murphy was convicted on all counts and sentenced to four years on the primary felony count and nine months on the misdemeanors, with a lifetime animal-possession ban on the cruelty counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did removals and related petitions destroy jurisdiction?	Murphy maintained the Superior Court lacked authority due to federal removals and petitions.	Murphy’s actions did not divest the state court of jurisdiction.	No jurisdictional defect; appeals rejected the arguments.
Were disruptions and claims against judges sufficient to bar participation?	Murphy argued ongoing actions against court participants barred proceedings.	Court properly managed disturbances without tainting proceedings.	Court acted appropriately; disruption did not invalidate trial.
Are the statutes underlying the prosecution unconstitutional?	Murphy claimed statutes were unconstitutional.	Statutes were valid and properly applied.	Claims deemed frivolous; no relief granted.
Is Murphy’s prior cruelty conviction void and the lifetime ban unenforceable?	Prior conviction and ban were invalid and unenforceable.	Prior judgment and ban were properly affirmed and enforceable.	Frivolous challenge; conviction and ban upheld.
Was the warrant supporting search and seizure overly broad?	Murphy argued the warrant was invalidly broad.	Warrant properly supported searches consistent with law.	Challenge deemed frivolous; evidence admissible.

State v. Estabrook, 2007 ME 130 (Me. 2007) (frivolous-review rule and protective restraints on disruptive conduct)
State v. Smen, 2006 ME 40 (Me. 2006) (court’s handling of disruptive defendants)
In re Michael M., 2000 ME 204 (Me. 2000) (standards for evaluating jurisdiction and due process)
State v. Barrett, 577 A.2d 1167 (Me. 1990) (recusal and handling of motions)
L'Abbe v. DiPaolo, 311 F.3d 93 (1st Cir. 2002) (limits on recusal and disruptive conduct in trial)
United States v. Brazel, 102 F.3d 1120 (11th Cir. 1997) (disruptions and fairness in criminal trials)
United States v. Beasley, 72 F.3d 1518 (11th Cir. 1996) (court’s management of disruptive defendants)
United States v. Stewart, 20 F.3d 911 (8th Cir. 1994) (defendant's right and courtroom conduct considerations)