State of Maine v. Corey W. Farley, 319 A.3d 1080

Corey W. Farley was convicted by a jury in Maine of gross sexual assault and unlawful sexual contact with an 11-year-old child who regularly stayed overnight at his home.
Farley was interviewed by a detective at his home in an unmarked police cruiser; he admitted to having sexual contact with the victim.
Farley moved to suppress his statements from the interview, arguing he was in custody (thus needing Miranda warnings) and that his hearing loss rendered the statements involuntary.
The trial court denied Farley's motions, found his statements voluntary and that he was not in custody during the interview, and admitted the statements at trial.
Farley also raised issues on appeal regarding the prosecutor’s statements at trial, claiming improper comments during closing arguments mischaracterized evidence, speculated about the meaning of text messages (“emojis”), and improperly vouched for witness credibility.
The Maine Supreme Judicial Court affirmed the convictions.

Issue	Farley's Argument	State's Argument	Held
Custodial Interrogation/Miranda	Farley was effectively in custody and required Miranda warning.	Farley was not in custody; warned he could stop at any time.	Not in custody; no Miranda warning required.
Voluntariness of Statements	Hearing loss/anxiety made statements involuntary.	No evidence of involuntariness; interview was conversational.	Statements were voluntary.
Prosecutorial Mischaracterization	Prosecutor misrepresented evidence about hearing/anxiety and victim credibility.	Any error was harmless; curative instructions given.	No prejudicial error; instructions adequate.
Prosecutor’s Interpretation of Emojis	Unsupported, prejudicial inference about sexual meaning of emojis in texts.	Inference supported; both victim and detective testified about meaning.	No obvious error; argument allowed based on the evidence.
Prosecutorial Vouching	Improperly vouched for victim’s truthfulness.	Remarks were tied to jury instruction on credibility evaluation.	No obvious error; comments tied to credibility, not personal opinion.

State v. Dion, 928 A.2d 746 (Me. 2007) (standards for custodial interrogation, voluntary statements)
State v. Ames, 155 A.3d 881 (Me. 2017) (review of suppression orders)
State v. Perry, 159 A.3d 840 (Me. 2017) (custody determination factors)
State v. Bethea, 221 A.3d 563 (Me. 2019) (curative instruction adequacy)
State v. Dolloff, 58 A.3d 1032 (Me. 2012) (prosecutorial error and harmless error)
State v. Seamon, 165 A.3d 342 (Me. 2017) (confession voluntariness standard)
State v. Glenn, 244 A.3d 1023 (Me. 2021) (voluntariness analysis)
State v. Cote, 159 A.3d 831 (Me. 2017) (fair argument based on evidence)
State v. Schmidt, 957 A.2d 80 (Me. 2008) (prosecutorial commentary on credibility)