State of Maine v. Crystal Palmer, 145 A.3d 561

Crystal Palmer pleaded guilty to endangering the welfare of a child and consented to a six‑month deferred disposition that required, among other things, a psychological evaluation and counseling with a parenting focus; if she complied she could withdraw her plea and the charge would be dismissed.
The written deferment forms mixed the psychological‑evaluation and counseling requirements in one sentence and separately listed counseling for parenting issues, creating unclear phrasing about whether the evaluation itself needed a parenting focus.
At the final hearing Palmer bore the burden to prove compliance; she submitted a psychological evaluation (late), had completed some parenting training, and had begun counseling late in the deferment period.
The State argued Palmer failed to obtain a psychological evaluation that “focused on parenting,” and the court concluded the deferment was “unsuccessful,” found noncompliance, entered judgment of conviction, and imposed jail and probation with similar conditions.
Palmer appealed, arguing the court erred by treating a parenting‑focused psychological evaluation as a required term (or that the term was ambiguous), and the Supreme Judicial Court vacated the judgment and remanded.

Issue	Palmer's Argument	State's Argument	Held
Whether the deferment required a psychological evaluation with a parenting focus	The agreement did not make the evaluation parenting‑focused; at most the counseling had that focus	The plain reading requires both the evaluation and counseling to focus on parenting	The clause is ambiguous; the court erred by treating a parenting‑focused evaluation as a definite requirement
Whether the trial court properly found Palmer failed to comply and that the failure was inexcusable	Palmer argued substantial compliance and offered explanations for delayed counseling and reports	State argued Palmer did not complete counseling or timely submit reports and thus failed the deferment	Court did not resolve other compliance issues; remand required for determination whether Palmer failed other terms and, if so, whether failures were inexcusable
Standard of review for factual findings at final deferment hearing	N/A (court sets standard)	N/A	Defendant has burden to prove compliance; appellate review of adverse factual finding requires record to compel contrary conclusion (deferential review)
Interpretation rule when deferment terms ambiguous	Ambiguities should be construed in defendant's favor	Ambiguities should be read to impose parenting focus on both evaluation and counseling	Ambiguous terms must be construed against the drafter; here ambiguity deprived Palmer of fair notice, requiring vacatur and remand

State v. Scott, 637 A.2d 1159 (Me. 1994) (question whether probation condition violated is factual; State bears burden in revocation motions)
State v. James, 797 A.2d 732 (Me. 2002) (review standard for factual findings in probation contexts)
State v. Pulsifer, 724 A.2d 1234 (Me. 1999) (trial court factual findings will be overturned only if record compels contrary conclusion)
Farrington’s Owners’ Ass’n v. Conway Lake Resorts, Inc., 878 A.2d 504 (Me. 2005) (contract interpretation, including ambiguity, reviewed de novo)
State v. Russo, 942 A.2d 694 (Me. 2008) (plea agreements are contracts and receive heightened scrutiny because of liberty interests)
Commonwealth v. Ruiz, 903 N.E.2d 201 (Mass. 2009) (probation conditions must be sufficiently precise; ambiguities construed in defendant’s favor)