State of Maine v. Julia Peck, 93 A.3d 256

Peck was charged in March 2012 with a civil cruelty to animals violation under 7 M.R.S. §§ 4011(1)(E), 4016(1).
The State and Peck reached an agreement allowing only one charged count while admitting evidence on 26 seized cats to address cruelty claims.
A three‑day bench trial was held with Peck unrepresented, and extensive evidence showed severe health problems among the cats.
Evidence showed the State spent about $36,800 to treat, house, and care for the 26 cats amid widespread disease and neglect.
On trial’s last day, the court quashed Peck’s subpoena for a vet witness due to late notice; the court then found cruelty and imposed a $500 fine, a $6,400 appeal bond, and an $18,000 restitution order (to be paid in installments), and limited Peck to two cats on her premises.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the subpoena quash was proper without a hearing	Peck	Peck contends improper quash without hearing	Quash not abused; no prejudicial error
Whether §4011(1)(E) is void for vagueness	Peck	Statute sufficiently defines ‘necessary medical attention’	Not void for vagueness; statute is intelligible
Whether evidence supports ‘necessary medical care’ finding	State	Peck provided some care; not enough	Evidence supports violation finding; cats’ conditions showed neglect
Whether restitution amount and method were proper	State	Court should have, possibly, greater capacity inquiry	Restitution properly reduced from $36,800 to $18,000 and payable in installments

State v. Grover, 387 A.2d 21 (Me. 1978) (nonparties may move to quash subpoenas; discretion to court)
State v. Watson, 726 A.2d 214 (Me. 1999) (court has discretion to quash subpoenas)
Shapiro Bros. Shoe Co., Inc. v. Lewiston-Auburn Shoeworkers Protective Ass’n, 320 A.2d 247 (Me. 1974) (due process requires intelligible standards in civil regulation)