State of Maine v. Jason J. Weaver, 130 A.3d 972

Weaver and the victim were in a relationship; in January 2014 an altercation occurred after Weaver tried to take the victim’s phone and a physical struggle ensued.
The victim sustained serious injuries (two broken eye sockets, fractured vertebral body, double vision, prolonged headaches and missed work).
State charged Weaver with aggravated assault (Class B) for serious bodily injury; Weaver pleaded not guilty, waived indictment, and was tried by jury.
Weaver’s defense: victim was the aggressor, lied or minimized her conduct, and Weaver acted in self-defense; Weaver did not testify but gave a police interview partly consistent with claiming self-defense.
At trial the prosecutor in rebuttal said the victim’s account was "credible" and corroborated by physical evidence; the court instructed the jury on self-defense but did not expressly tell jurors they must acquit if the State failed to disprove self-defense.
Jury convicted Weaver of aggravated assault; he appealed alleging prosecutorial misconduct, erroneous self-defense instruction, and insufficient evidence. The Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Weaver)	Held
Whether prosecutor’s closing statement that the victim’s version was "credible" was prosecutorial misconduct	Statement was a permissible comment that evidence corroborated the victim; not improper	Single comment vouched for victim and improperly invaded jury’s role, depriving fair trial	Not error: comment viewed in context was argument about corroborating evidence; jury instructed closings not evidence; no plain error
Whether self-defense jury instruction was legally erroneous post-Baker	Instruction adequately required jury to resolve self-defense before conviction; consistent and legally accurate	Instruction duplicated Baker’s structural flaws by not instructing that a not-disproved self-defense requires acquittal, creating manifest injustice	No obvious error: instructions were internally consistent and unlike Baker did not leave jury confused or with conflicting written instructions
Whether evidence was sufficient to support aggravated assault conviction and to disprove self-defense beyond reasonable doubt	Evidence (victim’s injuries, testimony, other physical evidence) permitted rational juror to find elements and disprove self-defense	Victim’s account was not credible; jury should have accepted Weaver’s self-defense theory	Sufficient: viewing evidence in State’s favor, jury rationally could find all elements and reject self-defense beyond a reasonable doubt

State v. Patton, 50 A.3d 544 (Me. 2012) (standards for viewing evidence in light most favorable to verdict)
State v. Dolloff, 58 A.3d 1032 (Me. 2012) (obvious-error review for unpreserved prosecutorial-misconduct claims)
State v. Schmidt, 957 A.2d 80 (Me. 2008) (permissible scope of argument about corroborating evidence and witness credibility)
State v. Corrieri, 654 A.2d 419 (Me. 1995) (closing argument must not urge decision on improper grounds)
State v. Baker, 114 A.3d 214 (Me. 2015) (defective self-defense instructions that produce structural error)
State v. Ashley, 666 A.2d 103 (Me. 1995) (standard for vacating judgment for obvious jury-instruction error)
State v. Reed, 58 A.3d 1130 (Me. 2013) (sufficiency-of-evidence standard)
State v. Cook, 2 A.3d 313 (Me. 2010) (credibility and weight of evidence lie with fact-finder)
State v. Glover, 594 A.2d 1086 (Me. 1991) (deference to jury on witness credibility)