State of Maine v. Joel A. Hayden, 2014 ME 31

Joel Hayden and Renee Sandora had a volatile relationship with addiction and jealousy; four children were involved.
Hayden spent time in rehab but resumed drug use, and he repeatedly accused Sandora of infidelity.
On July 25, 2011, Hayden shot Trevor Mills at Sandora’s home, then shot Sandora in view of their eldest son as Mills lay dying nearby.
Sandora called 911 during the incident, reporting Hayden’s threat to kill her in front of the children; Mills and Sandora died the following day.
Hayden fled in a black Cadillac, led police on a high-speed chase, and was apprehended after crashing in Lyman.
A .45-caliber Colt pistol and ammunition were linked to Hayden, with multiple shell casings and bullets recovered at the scene.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for murder	Hayden argues evidence only supports manslaughter due to intoxication.	State contends the evidence supports knowing/intentional murder beyond reasonable doubt.	Sufficient evidence supported murder beyond reasonable doubt.
Intoxication and culpable state of mind	Hayden’s intoxication negates intent.	Intoxication is considered but does not require the state to disprove voluntary intoxication beyond doubt.	Jury could rely on other evidence; intoxication not dispositive.
Basic versus maximum sentence and application of principles	Court misapplied sentencing principles in setting basic sentence.	Court properly weighed offense nature and Shortsleeves factors.	Court did not misapply principles; basic sentence deemed appropriate.
Aggravating factors and enhancement of sentence	Court erred in considering reoffense potential and trial-related impact on child.	Criminal history and other factors justify aggravation.	Court did not abuse discretion; substantial aggravators supported maximum sentence.
Right to a trial and potential punitive effect for going to trial	Sentence impermissibly punishs trial by jury.	Context of factors shows no improper punitive motive; analysis consistent with Farnham.	No unconstitutional punishment for exercising right to trial.

State v. Cookson, 2003 ME 136, 837 A.2d 101 (Me. 2003) (extreme cruelty, planning, execution justify severe basic sentence)
State v. Waterman, 2010 ME 45, 995 A.2d 243 (Me. 2010) (two-step process: basic and maximum sentences)
State v. Shortsleeves, 580 A.2d 145, 149-50 (Me. 1990) (Me. 1990) (aggravating factors guide distinguishing types of sentences)
State v. Holland, 2012 ME 2, 34 A.3d 1130 (Me. 2012) (selective execution as an aggravating factor)
State v. Farnham, 479 A.2d 887 (Me. 1984) (Me. 1984) (trial decision and right to a jury; context matters in sentencing)
State v. Grindle, 2008 ME 38, 942 A.2d 673 (Me. 2008) (trial right not to be punished; contextual sentencing factors)
State v. Dansinger, 521 A.2d 685 (Me. 1987) (Me. 1987) (punishment not solely for choosing a trial; consider other factors)
State v. Berube, 1997 ME 165, 698 A.2d 509 (Me. 1997) (probability of reoffending may be considered in aggravation)
State v. Michaud, 513 A.2d 842 (Me. 1986) (Me. 1986) (statutory framework for sentencing and consideration of offender characteristics)