State of Maine v. Thomas Bennett
2015 ME 46
| Me. | 2015Background
- Bennett, Saco Pawn and Loan employee, purchased items the victim knew were stolen during a burglary.
- Bennett did not disclose the stolen fishing reel to the victim when asked by the victim seeking his property.
- Police found the reel in the pawnshop, after which Bennett admitted purchasing it from McCurry.
- Jury convicted Bennett of Class D theft by receiving stolen property; he was sentenced to 14 days in jail and $500 fine plus surcharges.
- Bennett argued the sentence was illegal for disproportionality, equal protection, and due process reasons; the court affirmed the sentence.
- The court concluded Bennett’s direct appeal was proper for illegality challenges and affirmed the sentence on constitutional grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentence violates the Eighth Amendment or Maine Constitution. | Bennett claims disproportionate punishment. | State argues punishment is within statutory range and not grossly disproportionate. | No Eighth Amendment violation; sentence within allowed range. |
| Whether the sentence violated equal protection by targeting pawnshop employees. | Bennett argues disparate treatment for pawnshop employees. | Classification to pawnshop employees is rationally related to deterrence of theft. | Equal protection claim fails; rational basis found. |
| Whether due process was violated by reliance on unreliable or unrefuted information at sentencing. | Bennett contends information relied on was unreliable and unrefuted. | Court may rely on information that is factually reliable and relevant; allowed here. | Due process not violated; information relied on was reliable enough and the defendant had opportunity to respond. |
Key Cases Cited
- State v. Ricker, 770 A.2d 1021 (2001 ME 76) (review of sentence legality on direct appeal; due process considerations)
- State v. Harrell, 45 A.3d 732 (2012 ME 82) (de novo review of legality and constitutionality of sentence)
- State v. Cain, 888 A.2d 276 (2006 ME 1) (constitutional sentencing standards; due process)
- State v. Poole, 46 A.3d 1129 (2012 ME 92) (equal protection threshold; similarly situated analysis)
- United States v. Wilfred Am. Edu. Corp., 953 F.2d 717 (1st Cir. 1992) (due process considerations in sentencing; reliance on information)
- Williams v. New York, 337 U.S. 241 (1949) (courts may consider information beyond trial record at sentencing)