State of Maine v. Meggan M. Pratt, 243 A.3d 469

On Memorial Day weekend 2019, Meggan Pratt grabbed scissors during an argument with her 15-year-old daughter; later she smacked the daughter, leaving a bruise above the eye. The daughter later lived with foster parents.
Pratt was charged with domestic violence assault (17-A M.R.S. § 207-A(1)(A)) and tried by jury; both Pratt and the victim testified.
In her opening statement Pratt raised "family dynamics" and the parental-discipline justification (17-A M.R.S. § 106(1)) and also asserted self-defense; at trial the court and parties treated both defenses as at issue, though Pratt later waived the parental-discipline justification after close of evidence.
The prosecutor elicited testimony from the victim about Pratt’s parenting (e.g., not spending time, not cooking or doing laundry) over Pratt’s relevancy objections; the court allowed some latitude because Pratt had put parental discipline at issue.
Despite an earlier ruling sustaining an objection to questions about other children being removed from Pratt’s home, the prosecutor later asked Pratt about another child being "taken out of the house," and referred to the victim’s living situation in closing.
On appeal Pratt argued (1) the court erred by admitting testimony about parenting practices and (2) the prosecutor committed misconduct by eliciting/commenting on inadmissible evidence. The Maine Supreme Judicial Court affirmed the conviction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pratt)	Held
Admissibility of victim testimony about Pratt’s parenting practices	Testimony was relevant because Pratt raised parental-discipline justification in opening, so "family dynamics" bore on reasonableness of force	Testimony was vague, irrelevant to assault, and constituted inadmissible character evidence	Court: No clear error in admitting testimony; parental-discipline defense put parenting at issue, so evidence relevant to reasonableness and child’s behavior
Prosecutorial misconduct for eliciting/commenting on evidence that other children were removed from Pratt’s home	Questions/comments were fair given issues raised and some testimony already showed the victim did not live with Pratt	Prosecutor violated court ruling and elicited inadmissible, unfairly prejudicial evidence about other children being removed	Court: Prosecutorial misconduct occurred (plain error in eliciting inadmissible testimony) but error did not plainly affect outcome; conviction affirmed

State v. Ouellette, 208 A.3d 399 (Me. 2019) (standard for viewing evidence in light most favorable to State)
State v. Haji-Hassan, 182 A.3d 145 (Me. 2018) (review standards for evidentiary rulings)
State v. Dilley, 938 A.2d 804 (Me. 2008) (clear-error standard for evidentiary foundation)
State v. Dolloff, 58 A.3d 1032 (Me. 2012) (obvious error review and prejudice test for prosecutorial misconduct)
State v. Gaudette, 431 A.2d 31 (Me. 1981) (reversal where inadmissible hearsay from a judge likely improperly influenced jury)
State v. Collin, 441 A.2d 693 (Me. 1982) (improper admission may be harmless where other admissible evidence supports conviction)