Gauthier v. State
2011 ME 75
| Me. | 2011Background
- In October 2005, two murder victims were found in Lewiston; cause of death was blunt trauma to the head.
- In December 2005, police recovered items buried on property in Pownal stained with the victims' blood.
- Gauthier and Dyer were indicted in February 2006; Dyer confessed, but Gauthier did not initially incriminate himself.
- Trial occurred in October 2006; DNA linked both defendants to buried clothing stained with the victims' blood.
- Gauthier's theory of defense centered on him wearing a Red Sox jersey, not wielding the bat; Bruton concerns were resolved by severance pledges.
- After trial, Gauthier challenged trial counsel's effectiveness in post-conviction proceedings; court denied relief; this Court affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was counsel ineffective for choosing not to rest after State rested? | Gauthier argues failure to rest prejudiced defense. | Gauthier's defense strategy aimed to cast doubt on wearing the jersey. | No reversible error; strategy not ineffective. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance of counsel)
- McGowan v. State, 894 A.2d 493 (Me. 2006) (requires prejudice showing for ineffectiveness claim)
- Francis v. State, 938 A.2d 10 (Me. 2007) (implements standard for appellate review of post-conviction claims)
- Pineo v. State, 908 A.2d 632 (Me. 2006) (emphasizes deference to trial counsel's strategic decisions)
- Levesque v. State, 664 A.2d 849 (Me. 1995) (discusses level of deference to counsel's strategy)