State of Maine v. Craig A. Woodard, 334 A.3d 667

Craig A. Woodard was convicted by a jury of elevated aggravated assault, aggravated assault, and assault after a confrontation instigated by Facebook messages led to a prearranged fight at his home, culminating in Woodard shooting the victim as the victim retreated.
The trial court sentenced Woodard, merging the offenses and imposing a twelve-year sentence with all but five years suspended, three years of probation, and a mandatory minimum four-year term for use of a firearm.
Woodard argued for a jury instruction on defense of others (his girlfriend and daughter allegedly present), which the trial court did not provide, relying only on self-defense instructions.
On appeal, Woodard challenged the failure to instruct on defense of others, the application of the mandatory minimum firearm sentence, and consideration of his age and lack of remorse as aggravating factors during sentencing.
The Maine Supreme Judicial Court consolidated his direct and sentencing appeals for review.

Issue	Woodard's Argument	State's Argument	Held
Failure to instruct on defense of others	Jury should have been instructed on defense of others	Issue was waived; trial strategy focused on self-defense only	Waived by Woodard; no error.
Application of mandatory minimum sentence	Indictment did not cite sentencing statute or “firearm”	Indictment sufficiently alleged use of a "handgun," triggering mandatory minimum under statute	No error; indictment and proof sufficient for mandatory minimum.
Age as aggravating factor in sentencing	Unlawful to give aggravating weight to defendant’s age	Age is proper for individualized sentencing; not unduly weighted	No abuse of discretion; limited weight given to age.
Lack of remorse as sentencing aggravator	Sentencing error; judge relied on lawyer’s statements	Judge correctly relied on Woodard’s own statements showing lack of remorse	No error; court relied on Woodard’s statements, not counsel’s.

State v. Williams, 225 A.3d 751 (Me. 2020) (standard for reviewing unpreserved jury instruction errors)
State v. Nobles, 179 A.3d 910 (Me. 2018) (strategic waiver of jury instructions bars appellate review)
State v. Lopez, 184 A.3d 880 (Me. 2018) (review of the legality and constitutionality of sentences de novo)
State v. Pelletier, 306 A.3d 614 (Me. 2023) (indictment sufficiency and statutory pleading requirements)
State v. Brooks, 656 A.2d 1205 (Me. 1995) (indictment must give sufficient notice for enhanced sentencing)
State v. Bentley, 254 A.3d 1171 (Me. 2021) (broad discretion to courts in weighing sentencing factors)
State v. Bates, 822 A.2d 1129 (Me. 2003) (abuse-of-discretion review of sentencing factors)