State v. Caron
10 A.3d 739
| Me. | 2011Background
- Caron, while at the Springfield Fair, had been drinking earlier and participated in a truck pull, but was later refused participation due to concerns about sobriety.
- Caron insisted on driving after the victim took him to a convenience store and, upon leaving, he lost control and crashed, injuring both himself and the victim, with the victim left paralyzed from the waist down.
- A hospital blood-alcohol test within three hours of the crash showed Caron's BAC at 0.16%.
- Caron was indicted on aggravated assault (Class B) and aggravated OUI (two counts, Class C).
- The primary trial issue was identifying the driver; the State and Caron presented competing expert opinions, and redacted medical records were admitted.
- After trial, the jury found Caron guilty on all counts; a scheduling document listing Caron's prior OUI convictions was noticed, voir dire was conducted, mistrial denied, and judgment entered with concurrent and suspended portions and fines.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of the State's expert testimony | Caron argues the expert is incompetent/not qualified. | State contends the expert is qualified by experience and testimony supports his conclusions. | Expert qualified; admissible testimony. |
| Qualification of the State's expert on driver identity | Caron challenges the expert's specialized qualification to opine on driver identity. | State maintains general medical examiner expertise suffices. | Court did not abuse discretion; expert qualified. |
| Admission of redacted medical records | Exclusion required under Rule 403 or Confrontation Clause; records impermissibly admitted. | Redacted medical records may be admitted under 16 M.R.S. § 357; not prejudicial. | Admission was permissible; no reversible error. |
| Mistrial denial due to scheduling document | Scheduling document could prejudice jurors; mistrial warranted. | Individual voir dire protected jurors from prejudice; mistrial unnecessary. | No abuse of discretion; mistrial denied. |
| Sentence legality | Caron's sentence violated legality by improper factors. | Sentence properly considered trial conduct and related factors; not illegal. | Sentence affirmed as legal. |
Key Cases Cited
- State v. Manosh, 2010 ME 31 (Me. 2010) (courts view evidence in light most favorable to the State)
- State v. Gorman, 2004 ME 90 (Me. 2004) (test for witness competence includes reasonable ability to perceive)
- State v. Cochran, 2004 ME 138 (Me. 2004) (abuse of discretion standard for competency determinations)
- State v. Francis, 610 A.2d 743 (Me. 1992) (admission of medical records; Confrontation Clause considerations)
- State v. Bennett, 2006 ME 103 (Me. 2006) (Rule 403 and confrontation considerations in admitting medical records)
- State v. Bridges, 2004 ME 102 (Me. 2004) (mistrial standard; abuse of discretion standard)
- State v. Schmidt, 2010 ME 8 (Me. 2010) (sentence legality review on direct appeal)
- State v. Grindle, 2008 ME 38 (Me. 2008) (distinction between increasing sentence for trial exercise and genuineness of remorse)