State of Maine v. Roda O. Abdi State of Maine v. Ali-Nassir H. Ahmed, 112 A.3d 360

Abdi and Ahmed, claiming no/very low income, received Section 8 housing subsidies from 2002–2008 for a Lewiston apartment building.
They owned/operated A&R Halal Market and earned income well above Section 8 limits.
They provided false income/assets on NC/REMA forms (HUD Form 50059 and certifications) to obtain subsidies.
NC/REMA prepared and transmitted 50059 forms; subsidies were calculated to HUD and paid to landlords.
The trial court admitted the 50059 forms as business records under Evid. 803(6); defendants challenged admissibility and confrontation.
Convictions for theft by deception were entered after a joint bench trial; form authenticity and Confrontation Clause arguments were raised on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 50059 forms fall within the business-records exception.	Abdi/Ahmed contend forms fail 803(6) foundation.	State shows proper foundation via custodian Pelletier.	Yes; admissible under 803(6) with proper foundation.
Whether admission of the 50059 forms violated the Confrontation Clause.	Admission of forms without cross-examining preparers violated confrontations.	Business records created for HUD eligibility are non-testimonial.	Not violative of Confrontation Clause; forms not testimonial.

State v. Greenleaf, 2014 ME 89 (Me. 2014) (custodian testifies to business-records foundations; witness intimately involved in daily operations)
Murphy, 2011 ME 59 (Me. 2011) (admissibility of business records under 803(6); foundation requirements)
Barr v. Barr, 2010 ME 124 (Me. 2010) (custodian qualification under 803(6) admissibility)
Therriault, 485 A.2d 986 (Me. 1984) (lack of perfection in form does not defeat trustworthiness for 803(6))
Dolloff v. Dolloff, 2012 ME 130 (Me. 2012) (Confrontation Clause analysis for non-testimonial business records)
Olmo, 2014 ME 138 (Me. 2014) (evidence showing pattern of conduct may be admissible under other rules)