State of Maine v. Eric Hamel
2013 ME 16
| Me. | 2013Background
- Hamel was convicted by guilty plea to two counts of intentional or knowing murder for killing Victor Sheldon and Robert Day, as part of a plan orchestrated by Gayla Sheldon and Richard Moulton.
- Gayla Sheldon pled to conspiracy to commit murder and solicitation; Moulton pled guilty to two murders; Hamel’s sentence could be no more than fifty years under State agreement.
- The court used a two-step procedure under 17-A M.R.S. § 1252-C to set Hamel’s basic and aggravating/mitigating factors, resulting in a forty-five year term on each count.
- The court noted and adjusted for sentencing inequality among the participants, explaining Hamel’s more culpable conduct justified a longer sentence than Gayla’s and Moulton’s.
- The Maine Supreme Judicial Court granted leave to appeal and ultimately affirmed the sentence as properly calculated and justified.
- Gayla received 25 years with suspension and probation for two counts, Moulton 40 years for two murders, Hamel 45 years for two murders, all sentences concurrent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether Hamel's sentence violated statutory equality goals | Hamel argues longer term than co-defendants violates § 1151(5) | State contends nuanced conduct justifies different sentences | No; court accounted for inequality and differences in conduct, affirming sentence |
| whether proper sentencing procedure was followed | Hamel challenges procedure and information basis | Court properly applied two-step process and explained reasons | Yes; procedure followed and reasons articulated, sentence affirmed |
| whether disparities were justified by culpability | Hamel claims arbitrary disparity | Disparities reflect conduct differences; Hamel killed two victims | Yes; disparities supported by conduct and convictions |
Key Cases Cited
- State v. Reese, 991 A.2d 806 (2010 ME 30) (sentencing review discretion and statutory factors)
- State v. Koehler, 46 A.3d 1134 (2012 ME 93) (two-step murder sentencing procedure)
- State v. Stanislaw, 21 A.3d 91 (2011 ME 67) (importance of articulating sentencing rationale)
- State v. Dalli, 8 A.3d 632 (2010 ME 113) (affirming sentence with explicit consideration of sentencing purposes)
- State v. Houston, 534 A.2d 1293 (Me. 1987) (vacating sentence for unequal treatment of victims)
- State v. Mudie, 508 A.2d 119 (Me. 1986) (discretion in emphasizing sentencing goals)