State of Maine v. Dustin Brown, 158 A.3d 501

Background

On November 25, 2012, Dustin Brown was alone in a bedroom with his three‑month‑old son; within minutes the infant was limp, unresponsive, and later died at the hospital.
Brown first told others the baby went limp while being fed; later he said the baby’s head hit his chin and he reflexively pushed or jerked the infant away.
Autopsies by two forensic pathologists found subdural, subarachnoid, optic nerve sheath, and retinal hemorrhages consistent with inflicted traumatic brain injury from rotational/acceleration‑deceleration force; death occurred within about two hours of injury.
The pathologists testified the force required exceeded that from normal infant head movement or a simple chin bump; Brown’s expert attributed death to aspiration.
The trial court found Brown caused the fatal traumatic brain injury by acting with criminal negligence (a gross deviation from a reasonable person’s conduct) and convicted him of manslaughter; sentence was imposed and Brown appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove voluntariness and criminal negligence for manslaughter	State: Circumstantial and expert medical evidence sufficed to prove Brown inflicted fatal traumatic brain injury and acted with culpable negligence	Brown: State failed to prove how he injured the infant; his conduct was involuntary/reflexive and evidence does not show criminal negligence	Affirmed: Court held circumstantial evidence and expert testimony supported finding Brown inflicted the injury and acted with criminal negligence (gross deviation)
Whether conviction can rest without direct proof of the precise act	State: Direct proof unnecessary; fact‑finder may infer from timing, medical opinion, and defendant being sole caregiver when injury occurred	Brown: Lack of direct evidence of the specific act prevents proof beyond reasonable doubt	Held: Conviction may be supported solely by circumstantial evidence if it proves each element beyond a reasonable doubt
Whether trial court needed additional findings of fact	State: Court’s findings plus permissible inferences suffice	Brown: Court’s statements (e.g., "State has not proved exactly how this happened") undermine sufficiency	Held: No error; Brown did not request further findings under M.R.U. Crim. P. 23(c), and necessary factual findings are supported and may be inferred
Proper standard for assessing "reasonable and prudent" conduct	State: Court may apply common sense and jurors’ experience to determine gross deviation standard	Brown: State needed expert evidence on how a reasonable person would handle an infant because standard is not obvious	Held: Court permissibly relied on common sense; no requirement for expert testimony to define reasonable conduct

Key Cases Cited

State v. Murphy, 130 A.3d 401 (Me. 2016) (standard of review for sufficiency of evidence)
State v. McBreairty, 137 A.3d 1012 (Me. 2016) (fact‑finder may draw reasonable inferences and assess witness credibility)
State v. Cheney, 55 A.3d 473 (Me. 2012) (circumstantial evidence can support manslaughter conviction)
State v. Allen, 892 A.2d 447 (Me. 2006) (medical timing and being alone with victim support inferring inflicted injury)
State v. Chapman, 496 A.2d 297 (Me. 1985) (upholding manslaughter conviction without direct proof of the precise act)
State v. Tomer, 304 A.2d 80 (Me. 1973) (inferring defendant caused injuries from timing and exclusive access)
In re Ashley M., 754 A.2d 341 (Me. 2000) (shaking a baby can constitute gross deviation from reasonable conduct)
State v. Lowe, 124 A.3d 156 (Me. 2015) (jurors may use common sense to determine reasonable‑person standard)
State v. White, 460 A.2d 1017 (Me. 1983) (extremely vigorous shaking can show depraved indifference)