State of Maine v. Matthew Reed, 2013 ME 5

Reed Jabar was convicted of theft by unauthorized taking or transfer of property valued over $1,000 and criminal mischief based on his towing of a State Dodge Power Wagon from a federal excess lot.
Evidence showed Reed was found with tools in his truck and claimed he intended to use the axle to repair another truck he owned.
The federal excess lot is secured and houses state-owned, five-ton and other vehicles; cutting trees created a trail leading to the lot.
Rangers and a state trooper observed Reed arriving at the lot, hearing chopping noises, and stopping his vehicle after a forced confrontation.
The State presented testimony on the Power Wagon’s value and photographs; Reed testified to a different motive for moving the vehicle.
The jury found Reed guilty of theft in the $1,000–$10,000 range and criminal mischief; on appeal, Reed challenged the sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for theft value	Jabar: value exceeded $1,000, supporting Class C theft.	Jabar: value not proven beyond reasonable doubt.	Evidence supported value > $1,000 and ≤ $10,000.
Sufficiency of evidence for mischief	Jabar: actions showed intentional damage without lawful right.	Jabar: insufficient causation or intent.	Evidence supported intentional, knowing, or reckless damage without a right.

State v. Atkinson, 458 A.2d 1200 (Me. 1983) (conviction supported where defendant intended to steal property)
State v. Cook, 2010 ME 85 (Me. 2010) (elements of theft; circumstantial evidence allowed)
State v. Bruzzese, 2009 ME 61 (Me. 2009) (value of property; how to determine value for theft)
State v. Thibeault, 390 A.2d 1095 (Me. 1978) (evidence considerations for valuing property)
State v. Cyr, 389 A.2d 834 (Me. 1978) (circumstantial evidence can support criminal mischief conviction)
State v. Work, 603 A.2d 464 (Me. 1991) (circumstantial evidence sufficiency standard for conviction)