State of Maine v. Anthony W. Pratt Jr., 130 A.3d 381

Background

Victim Margarita Scott was in a relationship with Anthony Pratt Jr.; tensions arose because she maintained contact with her husband and wore his ring as well as Pratt’s.
On November 10, 2012, Pratt violently assaulted Scott at her Westbrook apartment; neighbors and others observed injuries and Scott reported pain and ringing in her ears.
Scott disappeared early on November 11; her body was later found in her truck with a fatal gunshot wound to the neck; forensic evidence linked Pratt to the gun at some point.
Pratt was interviewed twice by Detective Richard Vogel (one recorded interview in New York). Vogel repeatedly told Pratt he thought Pratt was lying; the second interview was played for the jury at trial.
Pratt was indicted for murder, moved in limine to exclude the recorded interview and evidence of the prior assault; the trial court admitted both with limiting instructions. Pratt was convicted and appealed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pratt)	Held
Admissibility of recorded interrogation (hearsay / Rule 403)	Recording is probative of defendant’s statements and demeanor; officer’s words provide context.	Vogel’s statements on recording are hearsay and should be excluded; prejudicial under Rule 403.	Admission proper: officer’s remarks were not offered for truth but for context; probative value outweighed prejudice.
Prosecutorial vouching via recorded interview	Playing the recording is not the prosecutor’s opinion and does not constitute vouching.	Vogel’s statements that Pratt was lying (and Vogel’s prominence at trial) equate to improper prosecutorial vouching.	No vouching: officer’s recorded belief differs from prosecutor’s opinion; jurors can distinguish roles.
Adequacy of limiting instruction for recorded statements	Limiting instruction allowed jury to consider officer statements only for context, not truth.	The instruction was insufficient to cure prejudice from Vogel’s statements.	No obvious error: defendant agreed to the instruction; instruction correctly stated law and jury presumed to follow it.
Admissibility of prior assault under Rules 404(b) and 403; due process claim	Prior assault evidence is admissible for motive, intent, identity, absence of mistake, and relationship; probative value high and limiting instruction mitigates prejudice.	Evidence was unfairly prejudicial, low probative value; limiting instruction on 404(b) insufficient; cumulative constitutional due process violation.	No error: evidence relevant to core issue (identity/motive); probative value not substantially outweighed by prejudice; limiting instructions adequate; no due process violation.

Key Cases Cited

State v. Mannion, 637 A.2d 452 (Me. 1994) (officer statements during interrogation admissible for context, not for truth)
Reardon v. Larkin, 3 A.3d 376 (Me. 2010) (standard for viewing facts in light most favorable to jury verdict)
State v. Schmidt, 957 A.2d 80 (Me. 2008) (prosecutor may not express opinion on defendant credibility)
State v. Wyman, 107 A.3d 641 (Me. 2015) (presumption that jury follows limiting instructions)
State v. Barnes, 845 A.2d 575 (Me. 2004) (Rule 404(b) permits prior-act evidence for motive, intent, identity, absence of mistake, or relationship)