State of Maine v. David W. Troy, 86 A.3d 591

On Feb. 27, 2012, David W. Troy appeared in Washington County Superior Court; the judge verbally ordered him into custody.
A corrections officer moved to handcuff Troy; Troy said “I’m not going to jail” (or similar), struck the officer in the chest, knocked her down, and fled the courtroom.
Troy jumped over the courtroom bar, ran through public areas of the courthouse toward the exit, and was apprehended at the base of the stairs by judicial marshals before exiting the building.
Troy was indicted for escape (Class B), assault on an officer (Class C), and criminal mischief (Class D); a jury convicted him of escape and assault on an officer and acquitted him of criminal mischief.
At trial a court clerk testified from an attested docket that the court had ordered Troy into custody; the docket itself was not admitted. Neither party objected to the clerk’s testimony.
Troy appealed, arguing insufficient evidence that (1) he was in custody pursuant to a court order, and (2) he left the courthouse (a required element, he claimed, for escape). The Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved Troy was in custody pursuant to a court order	State: clerk’s testimony and testimony of officers/marshal allowed jury to find Troy was ordered into custody	Troy: clerk’s testimony was inadmissible hearsay because the docket was not admitted; witnesses should not have testified to the court order	Held: Sufficient evidence; clerk’s testimony and officers’ observations supported that Troy was in custody; testimony about a judge’s courtroom order is admissible as direct observation and docket entries are admissible under public/business‑records exceptions
Whether Troy’s conduct constituted "leaving official custody" for escape	State: intentionally fleeing the corrections officer, evading marshals, and running through public courthouse areas constituted leaving official custody even though he did not exit the building	Troy: escape requires actual departure from the courthouse building	Held: Sufficient evidence; escape covers departure from custody/control (not limited to exiting the physical structure); his flight from officer control supported escape conviction

State v. Woodard, 68 A.3d 1250 (Me. 2013) (standard for reviewing sufficiency of the evidence)
State v. Duquette, 475 A.2d 1145 (Me. 1984) (testimony as to existence of court order placing defendant in custody presents no hearsay problem)
State v. Paradis, 10 A.3d 695 (Me. 2010) (interpret criminal statutes by plain language and statutory scheme)
State v. Patton, 50 A.3d 544 (Me. 2012) (unobjected‑to evidentiary rulings reviewed for obvious error)
State v. Campbell, 314 A.2d 398 (Me. 1974) (broad statement that escape is departure from custody before discharge by due process)