268 A.3d 281
Me.2022Background:
- Reeves was indicted in Maine for intentional or knowing murder after killing a companion in July 2017; he was arrested and incarcerated in New York on unrelated convictions.
- Maine lodged a detainer (Sept 2018); Maine obtained temporary custody Jan 22, 2020, starting the Interstate Compact on Detainers (ICD) 120-day trial clock (to May 21, 2020).
- COVID-19 pandemic and Maine Supreme Judicial Court pandemic-management orders suspended jury trials beginning mid‑March 2020; the trial court issued a written continuance in April 2020 after an unrecorded telephonic conference.
- Reeves moved to dismiss under the ICD for violation of the 120-day rule; the court denied the motion; jury trial began Sept 24, 2020; Reeves was convicted and sentenced.
- During trial bench conferences were conducted in the hallway for social‑distancing; Reeves later sought to discharge counsel and to represent himself mid‑trial; the court denied self‑representation and replacement of counsel.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ICD 120‑day dismissal | Reeves: 120 days expired; April continuance invalid because not granted "in open court" | State: 120‑day period was tolled because Reeves was "unable to stand trial" while jury trials were suspended by pandemic orders | Court assumed continuance invalid but ruled tolling applied for period when jury trials were suspended (Mar 13–Sep 7, 2020); fewer than 120 days elapsed; denial affirmed |
| Public‑trial right re: hallway bench conferences | Reeves: hallway bench conferences excluded public and violated Sixth Amendment public‑trial right (structural error) | State: Issue not preserved; brief bench conferences do not implicate public‑trial right; pandemic justified precautions | Issue unpreserved; reviewed for obvious error and failed—no plain error shown; claim rejected |
| Mid‑trial self‑representation | Reeves: constitutional right to self‑represention; requested mid‑trial | State: Right is limited after trial commences; court has discretion to deny untimely/self‑disruptive requests | Court held Maine Constitution permits limiting self‑representation once trial has begun; trial court reasonably exercised discretion after weighing factors; denial affirmed |
Key Cases Cited
- New York v. Hill, 528 U.S. 110 (U.S. 2000) (interpretation of ICD continuance provision)
- United States v. Kelley, 402 F.3d 39 (1st Cir. 2005) (standards of review for ICD claims)
- Presley v. Georgia, 558 U.S. 209 (U.S. 2010) (Sixth Amendment public‑trial right)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (constitutional right to self‑representation)
- Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (limits on self‑representation)
- United States v. Noah, 130 F.3d 490 (1st Cir. 1997) (untimely mid‑trial self‑representation and trial court discretion)
- State v. Beauchene, 541 A.2d 914 (Me. 1988) (Maine treatment of the ICD)
- State v. Rose, 604 A.2d 24 (Me. 1992) (prior Maine discussion of "unable to stand trial" tolling)