State v. Lopez, 184 A.3d 880

Lopez participated in a drug operation; after being robbed, he solicited a firearm from Mohamed and conspired with co-defendants to "recover" stolen property, which led to the shooting death of Charles Raybine by Nguany.
Police linked Nguany to the shooting via identification and ballistic evidence; Nguany was arrested with drugs and the matching firearm.
Lopez waived indictment and pleaded guilty to felony murder as part of a plea agreement that dismissed other charges and preserved his right to seek a lesser sentence than the State's recommendation.
At sentencing the State recommended up to 25 years (all but 15 suspended); Lopez sought a sentence mirroring Mohamed’s 7‑year term; Nguany received 40 years for pleading to murder and conspiracy, Mohamed received 7 years for conspiracy.
The court imposed a 20‑year sentence (10 years suspended), 4 years’ probation, and restitution, citing aggravating factors (drug involvement, harm to victim’s family, community impact) and mitigating factors (youth, prior good conduct, remorse, plea).
Lopez appealed, arguing the sentence was unconstitutionally disproportionate under the Maine Constitution and violated equal protection due to disparity with Mohamed’s sentence; the Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 20‑year sentence for felony murder is unconstitutionally disproportionate under Me. Const. art. I, § 9	Lopez: 20 years is grossly disproportionate to his role	State: 20 years falls within statutory range and reflects gravity and facts (drug involvement, solicitation of gun, causation)	Affirmed — not disproportionate; sentence within authorized range and consistent with punishment goals
Whether Lopez was denied equal protection because co‑defendant Mohamed received a much lighter sentence	Lopez: he and Mohamed had substantially similar roles, so disparate sentencing violated equal protection	State / Court: defendants not similarly situated — different pleas/charges and evidence strength; prosecutorial discretion explains disparity	Affirmed — no equal protection violation; different offenses and legitimate prosecutorial reasons justify disparity

State v. Ward, 21 A.3d 1033 (Me. 2011) (establishes Maine disproportionality test and distinguishes Maine constitutional protections from Eighth Amendment)
State v. Reardon, 486 A.2d 112 (Me. 1984) (upheld 20‑year sentence for felony murder as not shocking to public conscience)
State v. Stanislaw, 65 A.3d 1242 (Me. 2013) (discusses comparison of sentence to statutory maxima and similar cases in disproportionality analysis)
State v. Bennett, 114 A.3d 994 (Me. 2015) (limits appellate review to legality, not propriety, of sentences on direct appeal)
State v. Gilman, 993 A.2d 14 (Me. 2010) (proportionality review by reference to statutory sentencing range)
State v. Frye, 390 A.2d 520 (Me. 1978) (constitutional standard for disproportionality/cruel or unusual punishment)
State v. Vanassche, 566 A.2d 1077 (Me. 1989) (consideration of purpose and public interest in proportionality analysis)
Ewing v. California, 538 U.S. 11 (2003) (example of disproportionality discussion under Eighth Amendment)
State v. King, 330 A.2d 124 (Me. 1974) (recognizes imprisonment as an ordinary constitutionally defensible punishment)