State of Maine v. Danielle A. Beckwith, 117 A.3d 1049

Danielle Beckwith, supervisor in the Maine Judicial Branch Office of Transcript Production, approved and submitted a refund request resulting in a $2,750 refund check payable to her daughter, Alexandria ("Alex") Winchester. Beckwith and Alex shared a joint bank account.
The Office’s process: deposits are estimated, recorded in a database/form/logbook; supervisors sign refund forms which are routed to the Revenue Manager and then the State Controller for issuance of refund checks.
Office staff found no record of a $2,750 deposit or a Winchester order when the check arrived; the database later showed a backdated entry for an "Alec Winchester" original-order that was cancelled the same day as the deposit—contrary to usual practice and inconsistent with the known cost for a duplicate transcript.
Production staff observed Beckwith’s computer displaying the Winchester database entry and a Google search for "Alec Winchester." An internal investigation led to Beckwith’s termination and criminal charges.
Beckwith was charged with attempted theft by deception (attempt to obtain >$1,000) and two counts of tampering with public records or information based on (1) the false database/order entry and (2) the refund request form. After a bench trial the court convicted her of all counts and sentenced her to concurrent 60-day jail terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported attempted theft by deception (attempt)	State: Beckwith created a fictitious order and sought $2,750 refund; creating and submitting the refund check was a substantial step toward theft	Beckwith: Evidence insufficient to show intent or substantial step to steal State funds	Court: Evidence sufficient; backdated entry, Google search, receipt of check but termination before negotiation supported attempted theft conviction
Whether false entries in State records violate 17-A M.R.S. § 456(1)(A) (tampering)	State: Beckwith knowingly made false entries in government records to obtain refund; statute criminalizes making a false entry	Beckwith: Reliance on State v. Spaulding — tampering applies only to altering existing documents, not creating false entries	Court: Overrules portion of Spaulding; §456(1)(A) covers knowingly making false entries in governmental records; Beckwith guilty of two counts

State v. Spaulding, 707 A.2d 378 (Me. 1998) (past Maine decision limiting §456(1)(A) to alterations of existing documents; partially overruled here)
State v. Troy, 86 A.3d 591 (Me. 2014) (standard for viewing evidence on sufficiency review)
State v. Woodard, 68 A.3d 1250 (Me. 2013) (standard for sufficiency review of criminal convictions)
State v. Jones, 46 A.3d 1125 (Me. 2012) (interpretation favoring plain statutory language)