State of Maine v. Thayne M. Ormsby
2013 ME 88
Me.2013Background
- Three murders of Jeffery Ryan, his son Jesse Ryan, and Jason DeHahn, plus arson of Ryan’s truck, occurred in Amity in June 2010.
- Ormsby confessed to the killings to Maine State Police after extradition from New Hampshire.
- Ormsby was charged with three counts of murder and one count of arson; a two-stage trial was planned under 17-A M.R.S. § 40.
- The trial resulted in guilty verdicts on all counts and, in phase two, a finding of criminal responsibility; sentencing followed.
- The court imposed concurrent life terms for the murders and a consecutive fifteen-year term for arson; Ormsby appealed challenging suppression, insanity instruction, and sentences.
- The appellate court affirmed, upholding the suppression ruling, jury instruction approach, and sentencing framework.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the July 2, 2010 interview was custodial and tainted by invocation of rights. | Ormsby was in custody before the break and invoked rights. | Interrogation was custodial; rights were invoked; statements suppressed. | No custody before break; statements during first part admissible. |
| Whether Ormsby properly waived Miranda rights after the break. | Waiver ineffective due to prior invocation. | Waiver valid after second Miranda warnings. | Waiver valid; second part of interview admissible. |
| Whether the statements were voluntary for purposes of admissibility. | Statements tainted by coercive police conduct. | Statements were voluntary under totality of circumstances. | Voluntary confessions; admissible. |
| Whether the court should have instructed on insanity verdict consequences. | Need instruction to dispel belief insanity verdict frees defendant. | Okie precedent bars such instruction. | Insanity-consequence instruction rejected; Okie followed. |
| Whether consecutive arson sentence was proper alongside murder sentences. | Consecutive term for arson necessary; aggravation shown. | Consecutive sentence improper as part of same episode. | Consecutive arson sentence upheld; independent offense. |
Key Cases Cited
- State v. Vrooman, 2013 ME 69 (Me. 2013) (de novo review of suppression, factual findings respected)
- State v. Prescott, 2012 ME 96 (Me. 2012) (custodial analysis; post-invocation conduct relevant)
- State v. Nielsen, 2008 ME 77 (Me. 2008) (custody and Miranda invocation standards)
- State v. Ellison, 632 F.3d 727 (1st Cir. 2010) (federal custody and Miranda invocation framework)
- State v. Nightingale, 2012 ME 132 (Me. 2012) (custody determination factors; objective test)
- State v. Lavoie, 562 A.2d 146 (Me. 1989) (Miranda custody principles)
- State v. Okie, 2010 ME 6 (Me. 2010) (insanity verdict consequences not instructed absent empirical data)
- State v. Koehler, 2012 ME 93 (Me. 2012) (three-step sentencing framework for murder)