State of Maine v. Christopher Saenz, 2016 ME 159

Hilary Saenz died on December 25, 2013, from a subdural hematoma and a lacerated liver after repeated beatings over several days while her children were present.
Christopher Saenz, her husband, repeatedly assaulted her in the days before her death, causing extensive external and internal bruising, including multiple head injuries.
On the afternoon of her death, Saenz delayed obtaining emergency assistance: he searched the internet about being knocked out, called the hospital, called 9-1-1 (initial call failed), and waited over 30 minutes before a successful 9-1-1 call and ambulance arrival; Hilary’s pulse stopped soon after and she could not be revived.
Medical evidence established blunt-force trauma to the head and torso as the cause of death (subdural hematoma as immediate cause); Saenz’s experts disputed that a punch could cause such a hematoma and proposed a spontaneous seizure/fall as an alternative.
The trial court (bench trial; jury waived) found beyond a reasonable doubt that Saenz inflicted the fatal blunt-force head trauma within 36 hours before death (either directly or by causing a fatal fall) and that his prolonged abuse and delay in aid manifested depraved indifference to human life.
Saenz was convicted of depraved indifference murder (17-A M.R.S. § 201(1)(B)) and sentenced to 47 years; he appealed asserting insufficient evidence on causation and mental state.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Saenz)	Held
Causation: Did Saenz’s conduct cause Hilary’s death?	The blunt-force trauma Saenz inflicted caused the fatal subdural hematoma or caused a fall producing the hematoma.	Expert testimony said a punch is unlikely to cause a subdural hematoma; the hematoma likely resulted from a spontaneous seizure and fall unrelated to Saenz.	Court found evidence sufficient to conclude Saenz’s blows caused the fatal injury (directly or by causing a fall); it could reject defense experts and accept circumstantial and medical evidence.
Mental state: Did Saenz act with depraved indifference to human life?	Saenz’s repeated, escalating beatings over days and delay in seeking help demonstrated an objectively extreme risk of death and unjustifiable risk-taking.	Defense implicitly contended the lack of proof he subjectively appreciated such a risk and that the death resulted from an unforeseen medical event.	Court held the pattern of abuse and delayed aid supported a finding of depraved indifference beyond a reasonable doubt.

State v. Erskine, 889 A.2d 312 (Maine 2006) (standard for reviewing sufficiency of the evidence)
State v. Hodsdon, 135 A.3d 816 (Maine 2016) (deference to fact-finder credibility determinations)
State v. Stinson, 751 A.2d 1011 (Maine 2000) (permitting inferences from all circumstances despite contrary direct evidence)
State v. Crocker, 435 A.2d 58 (Maine 1981) (definition and standards for depraved indifference murder)
State v. Witham, 876 A.2d 40 (Maine 2005) (discussion of depraved indifference standard)

Judgment affirmed.