322 A.3d 1175
Me.2024Background
- Ronald Harding was convicted by a jury of manslaughter after the death of his infant son, based on injuries consistent with shaken impact syndrome.
- The incident occurred in May 2021, when Harding was alone with his infant, who became unresponsive and later died due to a traumatic brain injury.
- Medical evidence at trial indicated the fatal injury was acute and occuring while the child was in Harding’s sole care; defense posited alternative causes (COVID or earlier trauma).
- The prosecution emphasized the credibility of medical professionals over the defense’s paid expert during closing arguments.
- Defense objected to the prosecutor’s statements about the defense expert, asked for a curative instruction, then withdrew the request; no mistrial was sought.
- The jury found Harding guilty; he was sentenced to 15 years (8.5 years to serve) and appealed, arguing insufficient evidence and prosecutorial error.
Issues
| Issue | Harding's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of the Evidence | Injury could be from prior trauma or COVID, not provable Harding caused harm | Medical proof showed trauma while in Harding’s sole care, injury was acute | Sufficient evidence supports conviction; jury credibility determinations control |
| Prosecutorial Error in Closing | Prosecutor improperly attacked defense expert's credibility and vouched for state's witnesses | Prosecutor merely contrasted experts; inference allowed; no improper vouching | Error waived by defense’s actions; not preserved for appeal |
Key Cases Cited
- State v. Hansen, 228 A.3d 1082 (Me. 2020) (court recites facts in the light most favorable to the verdict)
- State v. Junkins, 789 A.2d 1266 (Me. 2002) (standard for sufficiency of the evidence on appeal)
- State v. Basu, 875 A.2d 686 (Me. 2005) (jury is sole judge of witness credibility)
- State v. Mazerolle, 614 A.2d 68 (Me. 1992) (conflicts in evidence resolved in favor of verdict)
- State v. Saenz, 150 A.3d 331 (Me. 2016) (appellate deference to jury’s fact-finding and credibility determinations)
- State v. Gove, 379 A.2d 152 (Me. 1977) (jury resolves factual disputes and credibility)