State of Maine v. Dylan Ketcham, 327 A.3d 1103

Dylan Ketcham was convicted of the murder of Jordan Johnson, attempted murder, and elevated aggravated assault of Caleb Trudeau following a 2020 altercation in Gardiner, Maine.
The incident stemmed from hostilities via phone and text between Ketcham and Johnson, resulting in a meeting where Ketcham shot Johnson and assaulted Trudeau with a machete.
Neither victim brought a weapon; the State presented evidence of premeditation by Ketcham, including theft of a gun and purchase of ammunition.
During trial, Ketcham sought to introduce text messages and conversations between the victims as evidence relevant to his self-defense claim.
The trial court limited the purpose for which the jury could consider these messages, finding no evidence that Ketcham was aware of them.
Ketcham appealed his convictions and sentences, challenging evidentiary rulings, competency evaluation procedures, and arguing the sentence constituted a de facto life term contrary to constitutional proportionality requirements.

Issue	Ketcham's Argument	State's Argument	Held
Limitation on text messages	Jury should consider victims' text messages as relevant to his self-defense belief and aggressor status	Messages irrelevant to self-defense since Ketcham was unaware; admissible only for limited purposes	Limiting instruction upheld as no evidence Ketcham knew of threats
Providing jury messages during deliberation	Jury should receive message printout since their contents were introduced	Only admitted evidence should go to the jury; printout not authenticated/admitted	Court properly withheld the printout; no abuse of discretion
Competency evaluation during trial	Court should have ordered evaluation based on defendant's demeanor	Counsel monitored and found Ketcham competent; court could rely on counsel	Court did not abuse discretion by relying on counsel's assessment
Sentencing constitutionality and proportionality	Combined sentence is an illegal de facto life sentence for a youthful offender	Sentence appropriate given crime gravity; consecutive sentences proper	Sentences (including consecutive terms) proportional and not grossly disproportionate

State v. Michaud, 724 A.2d 1222 (Me. 1998) (standard for viewing evidence in the light most favorable to the verdict)
State v. Penley, 288 A.3d 1183 (Me. 2023) (admissibility of hearsay under state-of-mind exception)
State v. Mitchell, 68 A.2d 387 (Me. 1949) (use of evidence of victim's threats in self-defense cases)
State v. Corbin, 759 A.2d 727 (Me. 2000) (jury access to admitted exhibits is at the trial court's discretion)
State v. Hewett, 538 A.2d 268 (Me. 1988) (court's duty to order competency inquiry)
State v. Stanislaw, 65 A.3d 1242 (Me. 2013) (Maine's proportionality review for sentences)