State of Maine v. Joshua T. Williamson, 163 A.3d 127

In August 2015 Williamson drank alcohol and used marijuana, then drove his girlfriend’s Jeep into her Ford; police later found him unsteady, slurring, and erratic. He called 9-1-1 at 1:54 a.m.; officers arrived ~10 minutes later.
At the station Williamson performed poorly on field sobriety tests, agreed to a breath test, predicted he would test “point 22,” and the Intoxilyzer result at 3:38 a.m. read 0.22 g/210 L.
Charged with OUI (Class D) and criminal mischief, Williamson went to a two-day jury trial; the State presented witness testimony, a 9-1-1 recording, bodycam excerpts, photos, and a certified Intoxilyzer printout.
Defense objected to admission of the Intoxilyzer result arguing the State failed to satisfy statutory foundation requirements (29-A M.R.S. § 2431(2) paragraphs H and I); initial objection sustained but result admitted after site coordinator testified about Department approval and calibration solution bearing a chemist’s initials.
Defense also objected when the State disclosed during trial that a State witness (the neighbor) had recently been investigated for accidentally shooting himself; defense claimed Brady violation but did not request relief (continuance, mistrial, in-camera review).
Jury convicted Williamson on both counts; he appealed contesting admission of the breath test result and alleging a Brady due-process violation. Judgment affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Intoxilyzer result under 29-A M.R.S. § 2431(2) (H & I)	State maintained it satisfied H (Department approval) and I (materials statement) through operator and site coordinator testimony and the chemist’s initials on solution	Williamson argued the State failed to prove paragraph I because no manufacturer/Department "statement" accompanied the calibration solution	Court held H was satisfied (waived challenge); paragraph I satisfied by chemist’s initials as a permissible form of "statement"; admission not an abuse of discretion or clearly erroneous
Late trial disclosure of witness investigation (Brady claim)	State disclosed the neighbor’s accidental-shooting investigation during the first day of trial and argued it was unrelated and not favorable to defense	Williamson argued nondisclosure violated Brady because investigative report could contain impeaching information and prejudiced his defense	Court held no Brady violation: State disclosed the matter promptly, the incident was unrelated and not evidently impeaching/exculpatory, and defendant showed no prejudice or requested remedial relief

State v. Atkins, 2015 ME 162 (Maine SJC) (describes elements the State may prove in OUI prosecution)
State v. Tozier, 115 A.3d 1240 (Me. 2015) (explains § 2431 framework for admitting breath test results and options to satisfy foundation)
State v. Gurney, 36 A.3d 893 (Me. 2012) (standard of review for admission of evidence over foundation objections)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose evidence favorable to accused that is material to guilt or punishment)
State v. Jobin, 510 A.2d 527 (Me. 1986) (applies Brady principles in Maine)
State v. Gould, 43 A.3d 952 (Me. 2012) (late disclosure context; not necessarily a Brady violation depending on circumstances)
State v. Jones, 55 A.3d 432 (Me. 2012) (standard of review for alleged due process violations)
State v. Twardus, 72 A.3d 523 (Me. 2013) (three-element test for Brady: favorable, suppressed, prejudicial)
State v. Kelly, 752 A.2d 188 (Me. 2000) (late disclosures and relevance to fairness of trial)
State v. Rourke, 154 A.3d 127 (Me. 2017) (viewing evidence in light most favorable to State on sufficiency review)
State v. Dube, 478 A.2d 1138 (Me. 1984) (remedies and relief tied to late disclosure; defendant’s failure to seek relief relevant)