State of Maine v. Neil D. Salisbury, 173 A.3d 146

Neil D. Salisbury was convicted by a jury in Hancock County of operating after suspension, operating without a license, and operating an unregistered vehicle (Class E offenses).
Salisbury appealed, primarily arguing the trial court lacked personal and subject-matter jurisdiction.
During trial Salisbury sought to subpoena the assistant district attorney; the court quashed that subpoena.
Salisbury raised additional claims at trial and on appeal (judge appointment, limits on his opening, jury instructions, a trespass counterclaim, and right-to-travel arguments).
The Maine Supreme Judicial Court reviewed the record, found Salisbury forfeited many arguments for lack of developed briefing, and addressed the adequately presented claims on the merits.
The court affirmed the conviction and rejected Salisbury’s substantive and procedural challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction (personal & subject-matter)	Court lacked jurisdiction over Salisbury	State: court had both personal and subject-matter jurisdiction	Court: jurisdiction proper; appeal rejected
Subpoena of ADA	Salisbury argued ADA should be compelled to testify	State: ADA had no relevant evidence; subpoena improper	Court: quash proper; ADA had no relevant evidence admissible under rules 401/402
Judicial appointment	Appointment was improper, affecting trial validity	State: judge properly appointed	Court: judge properly appointed; appointment challenge rejected
Limitation on opening statement	Salisbury argued time limits were unreasonable	State: limits were reasonable and within discretion	Court: limiting duration was a proper exercise of discretion
Jury instructions	Requested instructions should have been given	State: jury was fully and correctly instructed on applicable law	Court: denial proper; instructions sufficient
Trespass counterclaim in criminal trial	Salisbury sought to pursue a trespass claim during criminal prosecution	State: counterclaims not permitted in criminal proceedings	Court: no basis to hear trespass claim; criminal rules don’t allow counterclaims
Right to travel / interstate travel defense	Salisbury suggested travel rights barred prosecution	State: even interstate travel rights may be limited for public safety	Court: no interstate travel here; in any event states may limit travel for public safety; claim rejected

State v. Pelletier, 125 A.3d 354 (2015) (discussing jurisdictional and travel-related limits)
State v. St. Onge, 21 A.3d 1028 (2011) (jurisdiction principles)
State v. Watson, 726 A.2d 214 (1999) (subpoena and relevance standards)
Laprel v. Going, 96 A.3d 67 (2014) (judicial appointment validity)
State v. Liberty, 498 A.2d 257 (Me. 1985) (limits on opening statements)
State v. Hofland, 58 A.3d 1023 (2012) (jury instruction adequacy)
Saenz v. Roe, 526 U.S. 489 (1999) (right to travel and permissible state limitations)
State v. Elliott, 987 A.2d 513 (2010) (travel-rights precedent)
State v. Quinnam, 367 A.2d 1032 (Me. 1977) (travel and state regulation)
Mehlhorn v. Derby, 905 A.2d 290 (2006) (forfeiture for failure to develop appellate argument)