State v. Marquis, 162 A.3d 818

Victim was in an on‑and‑off relationship with Jesse Marquis; on the evening of May 30, 2014 they had a confrontation at a camp and then returned to the victim’s house.
Text messages from Marquis were found on the victim’s phone from the evening before and the same night; the State offered them to show Marquis’s state of mind shortly before the killing.
At dawn on May 31, 2014 witnesses heard a disturbance; witnesses saw Marquis with a knife and then a rifle; the victim was found dead from a contact rifle wound and multiple stab wounds.
Forensic evidence linked Marquis to the crime scene: spent cartridge matched his rifle characteristics, blood on a knife and in a rifle case matched parties, a bootprint matched his boot; Marquis was later arrested in the woods with cuts and a rifle nearby.
Marquis was indicted for intentional or knowing murder with use of a firearm; at trial the court admitted the text messages and three crime‑scene photographs and gave instructions on self‑defense and imperfect self‑defense; jury convicted and the court sentenced Marquis to life.

Issue	Plaintiff's Argument (Marquis)	Defendant's Argument (State)	Held
Admission of text messages — relevance	Messages from the night before were not temporally relevant to the murder	Texts showing Marquis was distraught/upset that night made intentional or knowing conduct more probable	Admitted: texts were relevant as circumstantial evidence of state of mind
Admission of text messages — foundation	Insufficient authentication that Marquis sent the texts	Phone belonged to victim; messages labeled “Jesse M”; corroborating witness recollection and event detail matched messages	Admitted: sufficient Rule 901 foundation for jury to determine authenticity
Jury instruction on self‑defense	Instruction was confusing and structurally flawed (per Baker) and deprived Marquis of fair trial	Instruction, taken as a whole, correctly stated law and required jury to resolve self‑defense before convicting	No obvious error: instructions were internally consistent and explicitly required acquittal if State failed to disprove self‑defense
Admission of crime‑scene photographs (Rule 403)	Photographs were highly inflammatory and prejudicial; probative value outweighed by prejudice	Photos were accurate, relevant to the scene and victim’s condition; jury already heard medical testimony about injuries	No abuse of discretion: probative value not substantially outweighed by unfair prejudice

State v. Weaver, 130 A.3d 972 (Me. 2016) (review of jury instructions as a whole and comparison to Baker)
State v. Gurney, 36 A.3d 893 (Me. 2012) (standards for relevance and foundation review of evidentiary rulings)
State v. Baker, 114 A.3d 214 (Me. 2015) (identifies structural flaws in self‑defense jury instructions)
State v. Allen, 892 A.2d 456 (Me. 2006) (three‑part test for admissibility of photographs: accuracy, relevance, Rule 403 analysis)
State v. Thompson, 503 A.2d 689 (Me. 1986) (threshold requirement for authentication under M.R. Evid. 901)
State v. Crocker, 435 A.2d 58 (Me. 1981) (photographs may be admissible despite gruesomeness where probative value is high)