State v. Koehler, 2012 ME 93

Koehler was convicted by jury of intentional or knowing murder and sentenced to life in prison under 17-A M.R.S. § 1251.
Evidence and trial rulings related to Koehler’s statements, jailhouse testimony, and weapon/photograph admissibility were challenged.
The state’s case included premeditation evidence and Koehler’s statements to police and others.
A pre-sentencing review incorporated psychological, psychiatric, and behavioral reports.
The court found premeditation and weighed aggravating vs. mitigating factors to impose a life sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of police and jailhouse statements	Koehler argues statements were improperly admitted	Court properly admitted voluntary statements after waiver of Miranda rights	Admissible statements upheld
Accomplice liability instruction	Instruction improper due to lack of evidence Koehler assisted in the murder	Instruction appropriate given potential accomplice theory	Instruction properly given
Validity of life sentence based on aggravating factors	Life sentence not supported by proper aggravating factors	Aggravating factors properly weighed against mitigating factors	Life sentence affirmed; weighing not improper

State v. Shortsleeves, 580 A.2d 145 (Me. 1990) (premeditation as a significant aggravating circumstance for life sentence)
State v. Waterman, 995 A.2d 243 (Me. 2010) (two-step murder sentencing framework; aggravators/mitigators then final term)
State v. Reese, 991 A.2d 806 (Me. 2010) (review of sentencing for abuse of discretion; factors weighed)
State v. Severy, 8 A.3d 715 (Me. 2010) (standards for reviewing sufficiency and evidentiary rulings)
State v. Caouette, 462 A.2d 1171 (Me. 1983) (accomplice liability instruction upholding)