State of Maine v. Anthony S. Leng, 244 A.3d 238

On January 7, 2018, Anthony S. Leng shot and fatally wounded his wife in their home while their two young sons were present; physical and forensic evidence showed multiple shots, including shots fired after the victim had collapsed, and the scene was staged to suggest self-defense.
Police recovered ten casings and ballistic evidence; the victim had multiple head/neck wounds and knives arranged around her; Leng remained alone in the house for ~15 minutes and then called 9-1-1 and later surrendered.
Leng was indicted for intentional and knowing murder, pleaded guilty in September 2019 pursuant to a plea agreement limiting recommendation to a 40-year cap, and the court accepted the plea.
At sentencing the court set a basic sentence of 50–55 years (citing domestic-violence context, prior threats, multiple shots including after collapse, children’s presence, and staging) and, after considering aggravating/mitigating factors, imposed a final 40-year term (within the plea cap).
Leng sought review, arguing the court erred at step one of the statutory sentencing analysis by failing to adequately compare his crime to similar murders; the Sentence Review Panel allowed appeal and the Maine Supreme Judicial Court affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing court misapplied step one of the sentencing analysis by failing to compare Leng’s crime to similar murders and thereby producing an excessive basic sentence	State: the sentence was appropriate; the court considered the cases presented and properly exercised discretion in weighing facts and comparable sentences	Leng: the court relied on a single case and did not adequately compare his offense to similar murders, undermining sentencing consistency	Court affirmed: no error; consideration of comparable cases is discretionary, the court considered parties’ submissions and a similar case, and the facts (children present, domestic-violence context, prior threats, staging, multiple shots) justified a high-end basic sentence and a 40-year final term

State v. Hayden, 86 A.3d 1221 (Me. 2014) (describes two-step sentencing process and basic-sentence inquiry)
State v. Nichols, 72 A.3d 503 (Me. 2013) (sentencing court has discretion to consider comparable sentences; not required to do exhaustive comparisons)
State v. Waterman, 995 A.2d 243 (Me. 2010) (presence of children at or near a murder is an aggravating factor raising conduct to the most serious level)
State v. Weyland, 240 A.3d 841 (Me. 2020) (children witnessing horrific family violence is a significant sentencing factor)
State v. Hutchinson, 969 A.2d 923 (Me. 2009) (children’s proximity to violent crime is an aggravating circumstance)
State v. Reese, 991 A.2d 806 (Me. 2010) (court has wide discretion regarding sources and types of information to consider at sentencing)