State v. George, 52 A.3d 903

George was convicted of intentional or knowing murder and conspiracy to commit murder in a joint trial with Williams.
George conspired with Williams and Cassimy prior to the 2008 murder of her husband in Old Orchard Beach during a simulated home invasion.
George testified before the York County grand jury on July 7 and September 2, 2008; she was not advised of her right against self-incrimination and was not told she was a potential suspect.
After indictments, the State moved to join George, Williams, and Cassimy for a single trial; Williams moved to sever, which the court denied.
George moved to suppress her grand jury testimony; the court denied the motion; Cassimy pled guilty and testified for the State; Williams testified for the defense.
At trial, George did not testify; the jury found George and Williams guilty of murder and conspiracy; sentences were imposed concurrently.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether grand jury suppression was properly denied	George asserts statements were involuntary and rights were violated.	George contends lack of warnings and coercive grand jury setting.	Denial affirmed; grand jury warnings not constitutionally required and testimony voluntary.
Whether severance was required for mutually antagonistic defenses	George argues joint trial with Williams prejudiced her defense.	Williams argues severance needed due to antagonistic defenses.	Joint trial permissible; no abuse in declining severance.
Whether indictment sufficiently charged murder and accomplice liability	Indictment failed to state elements of murder as principal or accomplice.	Indictment properly charged murder; accomplice liability need not be named separately.	Indictment sufficient; conviction valid under principal or accomplice theory.
Whether the evidence was sufficient to sustain murder and conspiracy convictions	Cassimy's testimony was credible and supported by other evidence.	Cassimy’s testimony was unreliable and conflicting.	Evidence sufficient to uphold murder, accomplice liability, and conspiracy convictions.
Whether the use of a cooperating witness rendered the conviction fundamentally unfair	Cassimy had motive to lie due to plea agreement.	Safeguards (cross-examination, disclosure, credibility instructions) mitigated risk.	No fundamental unfairness; safeguards were adequate.

State v. Williams, 2012 ME 63 (Me. 2012) (concurrent opinion; joint trial strategy context)
United States v. Washington, 431 U.S. 181 (U.S. 1977) (grand jury privileges and target warnings principles)
Mandujano v. United States, 425 U.S. 564 (U.S. 1976) (grand jury warnings not always required; awareness of Fifth Amendment rights)
Hoffa v. United States, 385 U.S. 293 (U.S. 1966) (cooperating witness credibility and due process safeguards)
Zafiro v. United States, 506 U.S. 534 (U.S. 1993) (mutually antagonistic defenses in joint trials)
State v. Lavoie, 1 A.3d 408 (Me. 2010) (voluntariness factors and totality of circumstances)
Dodge, 2011 ME 47 (Me. 2011) (standard of review for suppression rulings)