State of Maine v. Crystal Hodsdon
135 A.3d 816
| Me. | 2016Background
- From May 2009 to April 2013, Crystal Hodsdon, a DHHS eligibility specialist, represented to MaineCare that her two minor children lived with her at least 50% of the time.
- A 2008 divorce judgment allocated the children primarily to the father (Sunday evening–Friday evening) and to Hodsdon on weekends (Friday evening–Sunday evening), with shared holidays and a two-week summer period with Hodsdon. Occasional Sunday evenings with Hodsdon added only a half-day for some period.
- After marrying a MaineCare recipient, Hodsdon sought to add the children to her household on MaineCare forms and in an administrative hearing, stating schedules that overstated the children’s time with her.
- DHHS employees (including Hodsdon’s supervisor) handled her case; Hodsdon repeatedly asserted she had the children more than half the time and submitted supporting schedules and letters.
- After a bench trial, the Superior Court found Hodsdon “nowhere close” to meeting the 50% residence threshold, convicted her of theft by deception (Class B), and sentenced her with suspended time and restitution. Hodsdon appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved Hodsdon’s deception resulted in obtaining property (MaineCare benefits) | State: Hodsdon’s intentional misrepresentations led to receipt of Family Related 1931 MaineCare benefits, satisfying theft-by-deception elements | Hodsdon: The State failed to prove her deception caused a taking of another’s property beyond a reasonable doubt | Court: Affirmed — evidence showed Hodsdon intentionally deceived DHHS and obtained benefits, meeting the statute’s elements |
| Whether children lived with Hodsdon ≥50% of the time (eligibility threshold) | State: Documentary and testimonial evidence showed Hodsdon exaggerated time; children generally lived with father and thus did not meet the 50% rule | Hodsdon: She argued factual uncertainty and that she was close to or met the 50% threshold | Court: Affirmed — fact-finder rationally concluded Hodsdon was not close to 50% (defendant missed threshold by over 3 days/month) |
Key Cases Cited
- State v. Woodard, 68 A.3d 1250 (Me. 2013) (standard for reviewing sufficiency of evidence in criminal cases)
- State v. Barker, 387 A.2d 14 (Me. 1978) (false impressions may relate to state of mind in theft-by-deception prosecutions)
- State v. Black, 763 A.2d 109 (Me. 2000) (deference to fact-finder’s credibility determinations)
- Wilson v. Gordon, 354 A.2d 398 (Me. 1976) (fact-finder’s prerogative to resolve conflicting facts)