State of Maine v. Walter H. Renfro, 2017 ME 49

On Nov. 1, 2013, Waterville police stopped Walter Renfro; officer observed signs of intoxication and arrested him for OUI.
At the police station, an Intoxilyzer breath test produced a 0.17 g/210L result; Renfro was indicted for OUI and a license-condition violation.
An administrative hearing examiner later rescinded Renfro’s license suspension, finding the arresting officer failed to properly observe the required 15-minute pre-test period.
Before trial, the State sought to exclude evidence of the administrative decision; Renfro sought to admit it to challenge the Intoxilyzer result and impeach the officer.
The trial court admitted impeachment evidence that the officer had been “criticized” and a later video showing improved observation, but excluded the examiner’s written decision under M.R. Evid. 403 as unduly prejudicial.
A jury convicted Renfro of OUI; Renfro appealed, arguing the court abused its discretion in excluding the administrative decision (and also challenged denial of a mistrial on other grounds).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Renfro)	Held
Whether the trial court abused its discretion excluding the administrative hearing examiner’s decision about Intoxilyzer reliability	Exclusion proper under M.R. Evid. 403 because the examiner’s decision would unfairly lead the jury to substitute that decision for its own factual determination	The examiner’s decision was relevant and admissible impeachment evidence showing the breath test was unreliable	Court affirmed exclusion: probative value substantially outweighed by risk of unfair prejudice; jury might improperly substitute the administrative finding for its own beyond-a-reasonable-doubt determination
Whether the court erred in denying a mistrial for alleged improper burden-shifting in closing argument	No abuse; prosecutor did not impermissibly shift burden	Argued closing shifted burden, warranting mistrial	Court found no abuse of discretion and no prejudice to Renfro

State v. Kendall, 148 A.3d 1230 (Me. 2016) (standard for viewing evidence in the light most favorable to the State)
State v. Dean, 589 A.2d 929 (Me. 1991) (definition of unfair prejudice under Rule 403)
State v. Roman, 622 A.2d 96 (Me. 1993) (trial court’s broad discretion under Rule 403)
State v. Bennett, 658 A.2d 1058 (Me. 1995) (scope of impeachment testimony lies within judicial discretion)
United States v. MacDonald, 688 F.2d 224 (4th Cir. 1982) (exclusion of investigatory report to avoid undermining jury’s exclusive factfinding role)
State v. Huston, 825 N.W.2d 531 (Iowa 2013) (admission of administrative/substantiation findings can unfairly influence juries)