State of Maine v. James A. Reynolds, 193 A.3d 168

James A. Reynolds was indicted (Dec. 2016) and convicted after jury trial of multiple sex offenses arising from repeated sexual abuse of a girl from about age 9 to 16, including gross sexual assault, unlawful sexual contact, and sexual abuse of a minor. The indictment alleged one act per year from 1997–2002; one count was later dismissed pretrial.
Victim testified to an ongoing, weekly pattern of abuse (manual, oral, and genital contact) beginning at age nine and continuing until age sixteen; only a few discrete episodes were described in detail.
State sought and the trial court admitted limited references to uncharged acts (outside Oxford County) under M.R. Evid. 404(b); trial court prohibited detailed description of those incidents and the defense waived a limiting instruction.
Defense moved for judgment of acquittal asserting (1) lack of specific-unanimity support for eight of eleven counts, (2) unfair prejudice from admission of uncharged acts, and (3) two counts (1997, 1998) were time‑barred by a six‑year statute of limitations. The motions were denied; Reynolds was convicted and sentenced and appealed.
The Supreme Judicial Court affirmed: a properly instructed jury may convict on multiple counts supported by repetitive/generic testimony; admission of limited uncharged-conduct evidence was permissible; the 1999 legislative removal of the limitations defense applied retroactively to these juvenile-victim offenses.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Reynolds)	Held
Specific unanimity for multiple counts	Generic, repetitive testimony of weekly abuse across years sufficed, if jury received specific-unanimity instruction	Generic testimony only identified three discrete incidents, so jury could not have unanimously found additional eight charged acts	Court affirmed: where jury is properly instructed, credible generic testimony describing repeated, indistinguishable acts can support unanimous convictions on multiple counts
Admission of uncharged sexual conduct	Limited references to extra-jurisdictional/uncharged acts were admissible under M.R. Evid. 404(b) to show relationship, opportunity, intent	Admission invited the jury to punish for uncharged conduct and was unfairly prejudicial	Court affirmed: evidence admissible to show relationship/pattern; defendant waived limiting-instruction objection and failed to seek joinder relief or bill of particulars
Statute of limitations for 1997–1998 counts	Prosecution timely because 1999 Legislature removed the limitations defense retroactively for victims under 16 where the six‑year period had not yet run	Counts were governed by pre‑1999 six‑year limitations and prosecution in 2016 was time‑barred	Court affirmed: 1999 amendment removed limitations defense retroactively here; prosecution not barred; ex post facto claim rejected per Stogner

State v. DeLong, 505 A.2d 803 (Me. 1986) (uncharged-conduct evidence admissible to show relationship/opportunity under Rule 404(b))
State v. Hanscom, 152 A.3d 632 (Me. 2016) (specific-unanimity instruction required when identical crimes may be aggregated and jury must agree on a particular occasion)
State v. Shulikov, 712 A.2d 504 (Me. 1998) (repetitive-pattern testimony can support multiple-count convictions without discrete incident detail)
State v. Fortune, 34 A.3d 1115 (Me. 2011) (discusses aggregation of identical crimes in a single count and unanimity concerns)
People v. Jones, 792 P.2d 643 (Cal. 1990) (victim need not specify exact dates; must describe acts, general time period, and frequency to support multiple counts)
Stogner v. California, 539 U.S. 607 (U.S. 2003) (retroactive extension of limitations can raise ex post facto issues; distinguishes circumstances where prosecution was not previously barred)