State of Maine v. Bethany Ringuette, 288 A.3d 393

Victim, under age 12, was sexually assaulted by Travis Walker on three occasions; Ringuette encouraged and participated (told victim it was "okay," timed and showed actions during one episode).
Ringuette indicted for gross sexual assault (Class A) and sexual exploitation of a minor; convicted at bench trial of gross sexual assault under an accomplice-liability theory and acquitted of exploitation.
At sentencing the court applied the Hewey three-step framework, set the step‑one basic sentence at 20 years pursuant to 17‑A M.R.S. § 1252(4‑E), then reduced the maximum to 5 years after weighing aggravating/mitigating factors.
The court imposed 10 years of supervised release under § 1252(4‑E) but made no written findings explaining the supervised‑release length or conditions.
Ringuette appealed, arguing § 1252(4‑E) should not apply to an accomplice; the State conceded the court failed to make required supervised‑release findings.
The Maine Supreme Judicial Court affirmed the basic‑term decision (20 years) but remanded for the sentencing court to articulate Cook findings and determine appropriate supervised‑release length and conditions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1252(4‑E) (mandatory ≥20‑year basic term for § 253 offenses against <12) applies when defendant convicted as an accomplice	State: § 57 makes accomplices legally accountable as principals, so § 1252(4‑E) applies	Ringuette: statute shouldn’t apply because she was convicted as an accomplice, not a principal	Affirmed: accomplice is sentenced as if principal; § 1252(4‑E) mandates selecting a basic term of at least 20 years at step one
Whether the sentencing court erred by not making findings when imposing 10 years of supervised release	State: conceded error on lack of Cook findings	Ringuette: requested Cook findings to justify supervised‑release length/conditions	Remanded: court must determine appropriate supervised release and articulate Cook findings

State v. Hewey, 622 A.2d 1151 (Me. 1993) (establishes three‑step sentencing framework applied in Maine)
State v. Cook, 26 A.3d 834 (Me. 2011) (requires specific findings when imposing supervised release)
State v. Nguyen, 989 A.2d 712 (Me. 2010) (accomplice guilty as if a principal; verdicts indistinguishable)
State v. Carrillo, 248 A.3d 193 (Me. 2021) (whether defendant acted as principal or accomplice does not change statutory sentencing range)
State v. Cormier, 838 A.2d 356 (Me. 2003) (Criminal Code’s definition of accomplice liability applies broadly)
State v. Shortsleeves, 580 A.2d 145 (Me. 1990) (distinguishes legislatively mandated basic terms from sentencing enhancements)