State of Maine v. Jerry Lee Adams, 113 A.3d 583

Police stopped a vehicle in Old Orchard Beach; Jerry Lee Adams was a rear-seat passenger and fled on seeing officers prepare to search the car.
Officers apprehended and handcuffed Adams after a short foot chase; a pat-down revealed a leather pouch commonly used for digital scales.
Behind a nearby condominium, officers found a small backpack hanging on a fence with fresh footprints nearby; the backpack contained 28 small bags of a white substance, a digital scale (with a plastic cover), sandwich bags, and a phone.
The digital scale fit inside the pouch found on Adams’s person; Adams denied ownership of the backpack when asked at the scene.
A later search of a jacket matching Adams’s description yielded two cell phones; no forensic testing linked Adams directly to the backpack or its contents.
Adams was tried, convicted of aggravated trafficking and refusal to submit to arrest, and appealed the trafficking conviction challenging (1) exclusion of testimony characterizing the area as a “high crime” neighborhood and (2) sufficiency of the evidence (denial of judgment of acquittal).

Issue	State's Argument	Adams's Argument	Held
Whether the trial court erred in excluding testimony that the locale (Halfway area/Old Orchard Beach) was a “high crime” area	Exclusion proper because the proffered testimony was speculative and not sufficiently probative of who left the backpack	Evidence would show the area commonly has drug activity, making it plausible someone else left the backpack and undermining State’s ownership inference	Court affirmed exclusion: offer of proof was too speculative and not sufficiently relevant (M.R. Evid. 401–402); required foundation not shown; exclusion did not violate defendant’s constitutional right to present a defense
Whether evidence was sufficient to support aggravated trafficking conviction (possession/inference under 17-A M.R.S. §1103(3)(B))	Circumstantial evidence (flight, proximity to where backpack was found, pouch fitting the scale, fresh footprints, hiding near backpack) permitted reasonable inference of possession and guilt	Argued evidence failed to connect him to the backpack and drugs	Judgment of acquittal properly denied: viewed favorably to State, circumstantial evidence supported ownership of backpack and trafficking inference; conviction affirmed

State v. Dechaine, 572 A.2d 130 (Me. 1990) (admissibility framework for alternative-suspect evidence and relevance)
State v. Mitchell, 4 A.3d 478 (Me. 2010) (defendant’s right to present complete defense balanced against exclusion of marginally relevant evidence)
Holmes v. South Carolina, 547 U.S. 319 (2006) (trial court may exclude weakly relevant evidence to focus trial)
State v. Cruthirds, 96 A.3d 80 (Me. 2014) (standard for viewing evidence on appeal)
State v. Mills, 910 A.2d 1053 (Me. 2006) (probative-value assessment for contested evidence)
State v. Calor, 585 A.2d 1385 (Me. 1991) (indictments do not prove that crimes occurred)
State v. Woo, 938 A.2d 13 (Me. 2007) (circumstantial evidence can support conviction)
State v. Lambert, 363 A.2d 707 (Me. 1976) (possession inference precedent)