State of Maine v. Karl Maine, 155 A.3d 871

Karl Maine leased and operated Jake’s Diner; he was behind on rent and other bills and discussed financial troubles with acquaintances.
On Feb 12, 2014, security video from a market across the lot showed Maine approach the diner several times between ~4:55–5:03 p.m.; smoke was seen emerging ~5:05 p.m.
Firefighters extinguished a blaze that originated in a rear storage room; investigators (Young and insurance investigator Roy) concluded the fire was incendiary, likely ignited cardboard, based on damage patterns, smoke color, timeline, and elimination of accidental/natural causes.
William Shaw testified that before the fire he told Maine about a method to start fires (crossing water-heater wires) and that Maine discussed owing money to the market.
Maine’s motions to exclude the State’s fire-cause expert testimony and Shaw’s prior conversation were denied; Maine presented his own expert who disputed the State experts’ conclusions. A jury convicted Maine of Class A arson; sentence imposed and appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of State fire-cause expert testimony	State: experts used reliable investigative methods and scientific literature; conclusions tailored to facts	Maine: experts’ elimination-of-cause approach lacked scientific basis and was unreliable	Court: experts’ methods and conclusions met reliability indicia; admission not an abuse of discretion
Admissibility of Shaw’s testimony about fire-starting method	State: testimony shows Maine discussed arson in context of financial motives; probative of intent	Maine: low probative value, highly prejudicial, risk of jury misuse	Court: testimony had probative value and was not unfairly prejudicial; admission proper (any Rule 403 error harmless)
Sufficiency of evidence for intent and causation	State: timeline, video, smoke, damage patterns, expert testimony support that Maine entered and intentionally ignited storage-room cardboard	Maine: State failed to prove scientifically that fire was incendiary rather than accidental	Court: Viewing evidence in State’s favor, jury could rationally find Maine entered and intentionally set the fire; evidence sufficient
Standard of review for expert admissibility and evidentiary rulings	State: trial court applied appropriate reliability and abuse-of-discretion standards	Maine: contends stricter scientific causation required	Court: reviewed foundational findings for clear error and admissibility for abuse of discretion; applied established reliability indicia

State v. Troy, 86 A.3d 591 (Me. 2014) (standard for sufficiency review)
State v. Ericson, 13 A.3d 777 (Me. 2011) (indicia of expert testimony reliability)
Searles v. Fleetwood Homes of Pa., Inc., 878 A.2d 509 (Me. 2005) (clear-error review of expert foundational findings)
State v. Irving, 818 A.2d 204 (Me. 2003) (admission of expert opinion where multiple experts support methodology)
State v. DeMass, 743 A.2d 233 (Me. 2000) (harmless error analysis for evidentiary rulings)