State of Maine v. Elfido Marroquin-Aldana
2014 ME 47
| Me. | 2014Background
- Victim’s mother Lissette faced ongoing immigration issues; Marroquin-Aldana sought records to impeach her motive for a U visa.
- Lissette: Guatemalan immigrant with past deportation risk; obtained U visa later for cooperation.
- Marroquin-Aldana subpoenaed Lissette’s immigration records and petitioned for her attorney’s file.
- Trial court limited disclosure to protect confidentiality and refused production of attorney file; subpoena quashed.
- Defense argued records were necessary for motive impeachment; State argued subpoena was fishing expedition and unwarranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Immigration records subpoena scope | Marroquin-Aldana sought Lissette’s immigration records | Subpoena was a broad fishing expedition; not specific | Rule 17 qash upheld; no abuse of discretion |
| Effect of interpretation failures on due process | Interpreters failed to ensure accurate translation | Court promptly corrected issues; not reversible | No obvious error; trial fairness preserved |
Key Cases Cited
- State v. Watson, 1999 ME 41 (Me. 1999) (Subpoena duces tecum standards; abuse of discretion standard applied)
- State v. Patton, 2012 ME 101 (Me. 2012) (Obvious-error standard for unpreserved errors)
- United States v. Nixon, 418 U.S. 683 (U.S. 1974) (Rule 17-like standards; discovery limits in criminal cases)
- United States v. Morris, 287 F.3d 985 (10th Cir. 2002) (Subpoena specificity; fishing expedition concerns)
- United States v. Reed, 726 F.2d 570 (9th Cir. 1984) (Scope and specificity of subpoena requests)