State v. Haji-Hassan, 182 A.3d 145

In November 2014, Haji‑Hassan shot a man in a Portland apartment; the victim later died. Haji‑Hassan fled the scene and was later found in Minnesota, where he hid in a basement, emerged only after a police dog barked, and initially gave a false name to police. He was charged with intentional or knowing murder and later convicted by a jury.
Dr. Mark Flomenbaum, Maine's Chief Medical Examiner, performed the victim's autopsy and opined the defendant’s leg wound was consistent with a bullet wound occurring roughly eight weeks earlier.
The State moved in limine to exclude evidence that Dr. Flomenbaum had been removed as Massachusetts Chief Medical Examiner for administrative failures; the court ruled that the removal related to administrative, not pathologist, failings and excluded that evidence as irrelevant and potentially prejudicial while noting that trial testimony could "open the door."
The defense did not question Flomenbaum at trial about the Massachusetts removal or related Connecticut proceedings (in which a judge had found his testimony not credible), and no further rulings admitting that collateral evidence were made.
The court instructed the jury that evidence of flight to avoid prosecution may be considered as consciousness of guilt; Haji‑Hassan did not object to the instruction. The jury convicted; the defendant appealed challenging (1) exclusion of evidence about Flomenbaum’s removal and (2) the flight instruction.

Issue	Haji‑Hassan's Argument	State's Argument	Held
Exclusion of evidence that Dr. Flomenbaum was removed as MA Chief Medical Examiner	Removal was admissible to impeach Flomenbaum's credibility, show bias (to secure Maine job), and show specific untruthful conduct	Removal concerned administrative failures unrelated to his pathologist work; probative value low and admission would confuse jury/waste time	Court did not abuse discretion or commit clear/obvious error in excluding the removal evidence under Rules 401, 402, and 403; Confrontation Clause not violated
Admission of Connecticut judge’s prior credibility finding about Flomenbaum	That prior ruling was highly probative impeachment evidence	No ruling admitted that evidence; trial court only ordered disclosure; no preservation of issue	No preserved ruling to review; exclusion claim fails
Flight instruction to jury	Insufficient evidence to support inference of flight to avoid prosecution; instruction favored State	Evidence supported inference: immediate flight from scene, presence in Minnesota, hiding, false name; instruction allowed innocent explanations	Instruction proper; sufficient evidence supported it; no obvious error
Preservation / standard of review	Contends exclusion was error	State asserts trial rulings and lack of renewed proffers limited review	Appellate court applied clear error/abuse of discretion where preserved, and obvious error for unpreserved claims; defendant did not meet burden to show obvious error

Giglio v. United States, 405 U.S. 150 (1972) (prosecutorial disclosure obligations for witness credibility and impeachment)
Delaware v. Van Arsdall, 475 U.S. 673 (1986) (Confrontation Clause allows trial court latitude to impose reasonable limits on cross‑examination)
State v. Coleman, 181 A.3d 689 (Me. 2018) (discussion of admissibility of evidence concerning Flomenbaum’s Massachusetts removal in context of his qualifications)
State v. Cummings, 166 A.3d 996 (Me. 2017) (standard for viewing evidence in light most favorable to State)
State v. Fahnley, 119 A.3d 727 (Me. 2015) (standards for obvious‑error review and preservation on evidentiary rulings)