State of Maine v. Abdirahman H. Haji-Hassan, 182 A.3d 145

In November 2014 a victim was shot in a Portland apartment; Haji‑Hassan fled the scene and was later found in Minnesota where he initially gave a false name. He was charged with intentional or knowing murder and convicted by a jury in December 2016.
Dr. Mark Flomenbaum, Maine Chief Medical Examiner, performed the victim’s autopsy and opined a leg wound on Haji‑Hassan was consistent with a bullet wound.
The State moved to exclude evidence that Dr. Flomenbaum had been removed as Massachusetts Chief Medical Examiner for administrative failures; the trial court precluded that removal evidence as irrelevant to his pathologist testimony and as likely to provoke collateral, time‑wasting inquiry.
At trial neither party questioned Dr. Flomenbaum about the Massachusetts removal or the Connecticut judge’s adverse credibility finding; the court reminded that testimony could open the door to the excluded material, but no such questioning occurred.
The court instructed the jury that flight to avoid prosecution, if proven, may be considered as evidence of consciousness of guilt; Haji‑Hassan did not object to the instruction at trial.
Haji‑Hassan appealed, arguing (1) erroneous exclusion of evidence about Flomenbaum’s removal (and related Confrontation Clause and impeachment claims) and (2) improper jury instruction on flight; the Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Haji‑Hassan)	Held
Exclusion of evidence that Dr. Flomenbaum was removed as MA Chief Medical Examiner	Evidence was collateral and irrelevant to the pathologist opinion; admission would waste time and confuse jurors	Removal showed bias, lack of candor, and impeached his qualifications and truthfulness; thus admissible	Court affirmed exclusion: removal was administrative (not probative of pathologist competence), low probative value outweighed by Rule 403 dangers; no abuse of discretion or clear error
Jury instruction on flight to avoid prosecution	Instruction was proper and supported by evidence of flight and furtive conduct	Instruction improperly permitted an inference of guilt because evidence did not support flight-to-avoid-prosecution	Court rejected challenge: sufficient evidence supported inference of consciousness of guilt; instructions, read as a whole, were fair; no obvious error
Confrontation / cross‑examination claim tied to excluded removal evidence	N/A (State)	Exclusion violated Sixth Amendment right to effective cross-examination about potential bias/untruthfulness	Court held no Confrontation violation: trial court reasonably limited cross‑examination under Van Arsdall and Rule 403; alternative impeachment avenues existed

Giglio v. United States, 405 U.S. 150 (1972) (prosecution duty to disclose impeachment evidence bearing on witness credibility)
Delaware v. Van Arsdall, 475 U.S. 673 (1986) (Confrontation Clause allows reasonable limits on cross‑examination; trial judge has wide latitude)
State v. Cummings, 166 A.3d 996 (Me. 2017) (standard for viewing evidence in the light most favorable to the State)
State v. Fahnley, 119 A.3d 727 (Me. 2015) (preservation rules and review for obvious error)
State v. Lajoie, 154 A.3d 132 (Me. 2017) (review of jury instructions and evaluation of their adequacy)