State of Maine v. Dale M. Brackett, 300 A.3d 827

On May 17, 2020, a Dexter police corporal observed two motorcycles with nonworking taillights and began pursuit after activating cruiser lights; one motorcycle (Brackett's) initially slowed but then turned and fled.
With lights and siren fully activated, the corporal pursued; cruiser radar registered 93 mph as the cruiser passed from a 50 mph zone into a 35 mph zone.
Brackett was stopped, arrested, and initially issued summonses for failure to stop and criminal speeding; he was later indicted on those misdemeanors and a felony eluding-an-officer charge (29-A M.R.S. § 2414(3)).
At trial the State presented the corporal's testimony and cruiser video; the court instructed the jury using the Criminal Code definition of “recklessly” (17-A M.R.S. § 35(3)); neither party objected.
The jury convicted on all counts; postverdict the trial court granted Brackett’s motion for judgment of acquittal as to the felony eluding count, concluding the speed was not a “reckless rate of speed,” and imposed misdemeanor sentences.
The State appealed; the Supreme Judicial Court reviewed whether, viewing the evidence in the light most favorable to the State, a rational jury could have found the requisite reckless speed for eluding.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Brackett)	Held
Sufficiency: Did evidence support element of operating at a "reckless rate of speed" for eluding?	Radar showed 93 mph in 50→35 zones and a high‑speed chase; that supports a finding of reckless speed.	Speed was not reckless given clear conditions, light traffic, rider control, and alleged clutch issues; no one was endangered.	Reversed trial court: viewed most favorably to State, evidence rationally supports jury finding of reckless speed; vacate acquittal and remand for conviction/sentencing.
Jury instruction: Was instructing jury with 17‑A M.R.S. § 35(3) definition of "recklessly" erroneous and prejudicial?	State conceded the claim was unpreserved but urged any error was harmless.	Brackett did not object at trial; implicitly relied on that instruction.	Court treated the instruction as part of the record; even under that stricter statutory definition the evidence supports guilt, so any perceived error was harmless.
Definition scope: Must "reckless rate of speed" in §2414(3) be read apart from Criminal Code definition?	§2414(3) can be read by common meaning (Winchenbach), but here outcome is the same under either meaning.	Emphasized statutory instruction and contested factual circumstances.	Court noted Winchenbach but concluded that whether using common meaning or the statutory definition, the evidence sufficed.

State v. Winchenbach, 501 A.2d 1282 (Me. 1985) ("reckless rate of speed" may be treated by common meaning distinct from Criminal Code adverbial definition)
State v. Barnard, 772 A.2d 852 (Me. 2001) (standard of review for sufficiency of the evidence—view evidence in light most favorable to the State)
State v. Milne, 25 A.3d 943 (Me. 2011) (affirming eluding conviction where defendant drove at or in excess of high speeds during pursuit)