State v. Dalli, 2010 ME 113

Dalli killed Wheeler by stabbing him in the chest on September 2, 2008, after a night of drinking at Dalli's home where Wheeler and his girlfriend were present.
Dalli had a long-standing schizoaffective disorder with alcohol dependence and substance abuse, and a criminal history dating to 1978.
Initially charged with intentional or knowing murder; trial ended in mistrial; one month later Dalli pled guilty to manslaughter for recklessly or negligently causing Wheeler's death.
Sentencing followed 17-A M.R.S. § 1252-C's three-step process, with the court considering the offense's nature, Dalli's conduct and history, and mitigating/aggravating factors, aided by victim impact and letters from both sides.
The court imposed a 30-year maximum sentence, with 25 years as the basic sentence, and suspended 20 years; four years of probation were ordered after unsuspended time.
Dalli appeals the basic, maximum, and final sentence, arguing misapplication of principle and abuse of discretion; the Supreme Judicial Court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the basic sentence properly determined under §1252-C(1)?	Dalli argues the court misapplied principle by placing the basic sentence near the top of the range.	Dalli argues the court should have treated the offense as less serious or applied a different continuum.	No misapplication; analysis reasonably placed the offense near the upper end within the range.
Was the maximum sentence properly enhanced by mitigating and aggravating factors?	Dalli contends factors were misapplied or improperly weighted.	State contends the court properly weighed remorse, victim impact, record, and mental health history.	No abuse of discretion; factors balanced to justify the 30-year maximum.
Was the final sentence, including suspension and probation, an abuse of discretion?	Dalli argues the court failed to properly apply sentencing goals in suspending time.	State argues the court adequately considered gravity, public safety, deterrence, rehabilitation, and cooperation.	No abuse of discretion; final sentence consistent with statutory factors.

State v. Robbins, 999 A.2d 936 (Me. 2010) (three-step framework for setting basic and maximum sentences; de novo review for misapplication)
State v. Hutchinson, 969 A.2d 923 (Me. 2009) (continuum of seriousness for basic sentence; proximity to most serious form permissible)
State v. Reese, 991 A.2d 806 (Me. 2010) (affirms consideration of mitigating/aggravating factors and sentencing goals)