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State of Maine v. Nicholas Begin
120 A.3d 97
| Me. | 2015
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Background

  • Nicholas Begin appeals a conviction for assault on an officer (Class C), violation of a protective order (Class D), and refusing to submit to arrest (Class D).
  • The prosecution tried Begin for events on April 19, 2013, involving Lewiston Police Officer Vierling serving a protection order and Begin at 227 Bartlett Street.
  • Begin contended the trial court erred in admitting violent details from a prior unrelated incident (Webster Street) as probative but prejudicial.
  • The State introduced testimony that Begin violated a protection order and bail conditions by contacting Ashley, the protected party’s witness, affecting credibility.
  • Recorded jailhouse phone calls from Begin to his mother were admitted in part; Begin sought broader use of the recordings but was denied; jury found Begin guilty on all counts; he was sentenced to prison with suspended time and probation.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Webster Street testimony was unduly prejudicial under Rule 403 Begin argues the Webster Street details were unfairly prejudicial State contends relevance to Vierling’s state of mind; probative value not substantially outweighed by prejudice No abuse; testimony probative of state of mind and danger assessment.
Whether Begin’s contact with Ashley violated protection/bail orders admissibly affects credibility Begin challenges the credibility implications of contact Court could admit to assess bias and credibility Court did not abuse discretion; evidence probative of credibility and bias.
Whether the court erred by excluding portions of jailhouse recordings beyond context Begin sought broader use of recordings to supplement State’s evidence Court limited recordings to contextualize the State’s evidence No reversible error; court’s ruling not abused.
Whether prosecutorial remarks in opening statement warranted mistrial State comments improperly urged jury to convict or ‘hold accountable’ Remarks were improper but curable; court remedied prejudice Mistrial denied; prejudice remedied by court and instructions.

Key Cases Cited

  • State v. Haag, 2012 ME 94 (Me. 2012) (standard for reviewing evidentiary rulings; sufficient evidence viewed in State’s favor)
  • State v. Archer, 2011 ME 80 (Me. 2011) (Rule 106/for contextual evidence considerations (now Rule 403))
  • Dolloff v. State, 2012 ME 130 (Me. 2012) (prosecutorial misconduct remedies; preservation of jury neutrality)
  • State v. Woodard, 2013 ME 36 (Me. 2013) (prohibitions on appeals to public perception by prosecutors; remedy analysis)
  • United States v. Mandelbaum, 803 F.2d 42 (1st Cir. 1986) (prosecution urging conviction; improper exhortation contexts)
  • United States v. Castro-Davis, 612 F.3d 53 (1st Cir. 2010) (prosecutor arguments and jury pressure considerations)
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Case Details

Case Name: State of Maine v. Nicholas Begin
Court Name: Supreme Judicial Court of Maine
Date Published: Jul 16, 2015
Citation: 120 A.3d 97
Docket Number: Docket And-14-308
Court Abbreviation: Me.