State v. Gould
2012 ME 60
| Me. | 2012Background
- Gould was convicted of gross sexual assault Class A and Class B after a jury trial in Aroostook County.
- Interrogation occurred May 22, 2007 in a police car; a DHHS caseworker was present initially.
- Gould was read Miranda rights, waived them, and gave a lengthy confession during a noncustodial interview.
- A forensic report about PSA and seminal fluid on the victim’s bed sheet was prepared; no sperm cells were found and DNA testing capacity at the time was limited.
- Gould sought suppression of the confession; the trial court ruled the interview was voluntary and noncoercive.
- Gould challenged the timing and handling of discovery, Brady materials, and prosecutorial remarks in closing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Gould's confession voluntary? | Gould argues coercive assurances violated voluntariness. | State contends interview was noncustodial and counseling promises were not coercive. | Confession voluntary; no reversible coercion found. |
| Did prosecutorial misstatement deny a fair trial? | Prosecutor misstated DNA evidence by claiming bed sheet washed, contrary to record. | Statement was inference based on evidence; not misconduct. | No obvious error; not undermining fairness. |
| Did discovery violations require a new trial or sanctions? | Late lab report disclosure prejudiced defense and violated Rule 16 and Brady. | Disclosures were timely; no prejudice; not Brady material. | No abuse of discretion; defendant not prejudiced; sanctions not warranted. |
Key Cases Cited
- State v. Dodge, 2011 ME 47 (Me. 2011) (voluntariness review; factual findings deferential, legal standards de novo)
- State v. Lavoie, 2010 ME 76 (Me. 2010) (Miranda and voluntariness under totality of circumstances)
- State v. Williams, 2011 ME 36 (Me. 2011) (noncustodial interrogation in police car)
- State v. Schmidt, 2008 ME 151 (Me. 2008) (obvious error standard for prosecutorial misstatement)
- State v. Ardolino, 1997 ME 141 (Me. 1997) (reasonableness of inferences from evidence)
- State v. Roberts, 2008 ME 112 (Me. 2008) (fairness of prosecutor’s statements based on evidence)
- State v. Clark, 2008 ME 136 (Me. 2008) (prosecutorial conduct; whole-record approach)
- State v. Kelly, 2000 ME 107 (Me. 2000) (pretrial awareness of exculpatory evidence and due process)
- State v. Dube, 478 A.2d 1138 (Me. 1984) ( Brady principle application in Maine)