State of Maine v. Chuck D. Schooley, 2025 ME 84

Chuck D. Schooley was convicted of gross sexual assault (Class A) involving a child under twelve and violating a condition of release, based on events occurring between 2020 and 2022.
The victim, Schooley's stepdaughter, testified to repeated sexual abuse over several years, including three specific incidents with detailed descriptions.
The only evidence at trial was the victim's testimony; no corroborating evidence was given. Schooley did not testify.
Defense counsel focused on attacking the victim’s credibility, alleging inconsistencies and arguing the events could not have occurred as described.
The trial court delivered general jury instructions on unanimity but did not address specific unanimity (requiring the jury to agree on the same act as the basis for conviction), and neither party requested such instruction.
Schooley appealed, arguing for reversal based on the absence of a specific unanimity instruction and improper prosecutorial statements during closing argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Absence of Specific Unanimity Instruction	Failure to instruct on specific unanimity was obvious error, prejudicing jury deliberations	Evidence supported multiple acts; a general unanimity instruction sufficed	No plain error; not likely jury was confused
Prosecutorial Error in Closing	Prosecutor improperly vouched for witness and appealed to sympathy	Statements proper, based on evidence and credibility assessment	No plain error; did not affect substantial rights

Andres v. United States, 333 U.S. 740 (1948) (requiring jury unanimity in criminal convictions)
Ramos v. Louisiana, 590 U.S. -- (2020) (Sixth Amendment unanimity applies to state trials)
State v. Hanscom, 2016 ME 184 (Maine: specific unanimity required if multiple incidents alleged)
State v. Reynolds, 2018 ME 124 (jury can convict based on generic testimony if they agree on pattern of abuse)
State v. Pabon, 2011 ME 100 (standard for plain error review in jury instructions)