103 A.3d 1026
Me.2014Background
- Stephen Treadway was convicted of assault and domestic-violence assault after a jury trial in Washington County, Maine.
- Victim is Treadway’s fourteen-year-old son who lived with his mother, with Treadway having not cohabited for years.
- Event occurred September 18, 2013 when Murphy found the son on the porch and Treadway confronted him about marijuana use.
- Treadway dragged the victim, pinned him, struck him with an open hand, grabbed his necklace, punched him, and then kicked him.
- Bruising and a red mark were observed; the victim missed school to avoid explaining injuries; the evidence was offered to test the parental-discipline justification under 17-A M.R.S. § 106(1).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State disproved the parental-discipline defense beyond a reasonable doubt. | Treadway | State must disprove the defense beyond reasonable doubt | Yes; evidence sufficed to disprove the defense beyond a reasonable doubt |
Key Cases Cited
- State v. Cook, 2010 ME 81 (2010) (discusses parental-discipline justification framework)
- State v. Wilder, 2000 ME 32 (2000) (precedes that coercive force may be justified under certain circumstances)
- State v. York, 2001 ME 30 (2001) (defines reasonable, prudent-parent standard for necessity of force)
- State v. Haag, 2012 ME 94 (2012) (describes sufficiency review and reasonable-doubt standard)