240 A.3d 841
Me.2020Background
- Weyland and the victim were estranged spouses with two children; after a judicial decision awarding the victim primary custody, Weyland told her mother she “wanted [the victim] dead,” then drove to his home and fatally stabbed him while the children were present.
- Police found the victim’s cell phone near a barn; the son attempted emergency care and witnessed events.
- Weyland was charged with knowing or intentional murder and violation of a protective order; she entered an unconditional guilty plea to murder on August 27, 2018 under a plea agreement in which the State would dismiss the protection-order charge and recommend 25–32 years.
- On October 26, 2018, before sentencing, Weyland moved to withdraw her plea, asserting she had not taken prescribed medications at the Rule 11 hearing, had limited cognitive capacity, and therefore did not understand the mens rea element.
- After an evidentiary hearing, the trial court found Weyland was coherent and engaged at the Rule 11 hearing, had taken her medications as prescribed, did not credibly link any abnormal mental condition to an inability to form mens rea, and denied withdrawal; at sentencing the court set a basic term of 45 years and a maximum of 32 years, and entered a 32-year sentence.
- Weyland appealed both the denial of her motion to withdraw and the sentence; the Supreme Judicial Court affirmed judgment and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Motion to withdraw plea based on alleged lack of understanding (medication/capacity) | Weyland: she skipped meds and has limited cognition, so her plea was not knowing and should be withdrawn promptly. | State: record and counsel reports show she was coherent, understood the charge, and had taken meds; delay and lack of credible evidence weigh against withdrawal. | Denial affirmed — court did not abuse discretion; Rule 11 adequate and plea knowing. |
| Claim of innocence via "abnormal condition of the mind" (negating mens rea) | Weyland: expert diagnoses (TBI, PTSD, depressive/anxiety disorders) could raise reasonable doubt on mens rea under 17-A M.R.S. § 38. | State: expert did not link diagnoses to inability to form mens rea; undisputed facts show deliberate, goal-directed conduct inconsistent with lack of culpable state of mind. | Held against Weyland — she failed to proffer evidence connecting condition to incapacity to form mens rea; assertion not credible. |
| Sentencing: misapplication of principles; should be treated as manslaughter | Weyland: crime more akin to manslaughter; court should have imposed lesser sentence. | State: court properly applied two-step murder sentencing, weighed aggravating/mitigating factors (children witnessed, deliberate conduct) and reduced basic 45-year term to 32 years. | Sentence affirmed — no error in principle or application; murder conviction and 32-year term supported by record. |
Key Cases Cited
- State v. Hillman, 749 A.2d 758 (Me. 2000) (factors for evaluating pre-sentence plea-withdrawal motions)
- State v. Lambert, 775 A.2d 1140 (Me. 2001) (timeliness and delay in plea-withdrawal analysis)
- State v. Giroux, 113 A.3d 229 (Me. 2015) (no single factor dispositive; evaluate plea-withdrawal factors collectively)
- State v. Malo, 577 A.2d 332 (Me. 1990) (defendant must proffer evidence linking mental condition to inability to form culpable state of mind)
- State v. Proia, 168 A.3d 798 (Me. 2017) (court’s role when abnormal condition of mind evidence is presented)
- State v. Waterman, 995 A.2d 243 (Me. 2010) (impact of children witnessing horrific violence is significant at sentencing)
- State v. Lord, 208 A.3d 781 (Me. 2019) (two-step process for murder sentencing: basic and maximum terms)
- State v. Boone, 444 A.2d 438 (Me. 1982) (court may infer competence from rational, coherent answers at plea proceedings)
