Donald Beauchene v. State of Maine, 167 A.3d 569

In 1970 Beauchene was found not guilty of murder by reason of mental disease or defect and committed to Department custody; he remained committed and filed a petition in 2016 under 15 M.R.S. § 104-A seeking discharge or modified release.
At trial in 1970 experts differed; the jury accepted Beauchene’s theory (described then as “explosive personality”) and returned the NGRI verdict.
Evidence at the 2016 hearing showed longstanding personality/behavioral symptoms consistent with antisocial traits, escape history, conviction in New York in 1980 for sexual offenses, lack of insight, deceitfulness, and grooming behaviors toward vulnerable women.
Three mental-health experts at the 2016 hearing testified that Beauchene’s symptoms have remained essentially unchanged since 1970 and continue to present a risk of harm to others.
The superior court found he still suffers from a mental disease or defect and poses a danger; it denied the petition. Beauchene appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence compels finding no mental disease or defect	Beauchene: evidence shows only antisocial personality disorder, which as a matter of law is not a "mental disease or defect," so he never met that standard	State: jury in 1970 found mental disease/defect; court may apply legal standard to psychiatric evidence and experts say symptoms persist and are dangerous	Court: Affirmed — evidence did not compel contrary finding; court properly concluded he continues to suffer a mental disease or defect and is dangerous
Whether 15 M.R.S. § 104‑A is unconstitutionally vague	Beauchene: terms like "likelihood," "injury," and unspecified time horizons fail to give adequate notice and invite arbitrary enforcement	State: statute gives reasonable, fact‑specific standards for courts to determine risk; broad terms are appropriate for judicial factfinding	Court: Rejected vagueness claim — statute provides sufficient notice and is reasonably construed case‑by‑case
Whether continued confinement violates due process	Beauchene: confinement not narrowly tailored; alternative (involuntary commitment statutes) could apply	State: confinement is lawful where person is mentally ill and dangerous; procedural posture of acquittee appropriate	Court: Rejected due process claim — confinement permissible so long as mentally ill and dangerous (Foucha)

Begin v. State, 153 A.3d 93 (Me. 2016) (states burden and clear‑and‑convincing standard for acquittee seeking release)
Beal v. State, 151 A.3d 502 (Me. 2016) (term "mental disease or defect" is a legal concept for the court to determine)
Green v. Comm’r of Mental Health & Mental Retardation, 750 A.2d 1265 (Me. 2000) (state may confine those mentally ill and dangerous; outlines release inquiry)
Foucha v. Louisiana, 504 U.S. 71 (1992) (due process permits continued confinement while individual remains mentally ill and dangerous)