State v. Matatall, 196 A.3d 1293

Scott F. Matatall was charged with OUI with one prior (Class D) and pled not guilty; jury trial held January 10, 2018.
The State possessed a police-station video showing Matatall allegedly intoxicated and refusing an Intoxilyzer; disclosure to defense occurred two days before trial (counsel got copy the day before).
Defense moved immediately before trial to exclude the video under M.R.U. Crim. P. 16 for late disclosure.
Trial court excluded the video from the State’s case-in-chief as a discovery sanction but ruled the State could use it to impeach Matatall if he testified and clearly contradicted the recording.
Matatall testified, contradicted the video, the court allowed the video for impeachment, the jury found him guilty, and judgment (sentence) was entered; Matatall appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the late-disclosed video must be excluded for all purposes as a discovery sanction	State: discovery violation occurred but court can fashion sanction; should be able to impeach if defense opens the door	Matatall: video should be entirely excluded; Rule 16 violation cannot be used to impeach him	Court affirmed: trial court acted within discretion—exclude from case-in-chief but permit use for impeachment if defendant testifies inconsistently
Whether allowing impeachment with excluded evidence deprives defendant of a fair trial	State: limited remedial use prevents prejudice and is reasonable	Matatall: impeachment use effectively nullifies sanction and prejudices defendant	Court: sanction struck appropriate balance; defendant not deprived of fair trial under Leavitt/Landry principles

State v. Landry, 459 A.2d 175 (Me. 1983) (a defendant may not use a discovery violation as a shield to prevent admissible rebuttal evidence when defendant testifies inconsistently)
State v. Leavitt, 625 A.2d 302 (Me. 1993) (trial court has discretion to fashion sanctions under Rule 16; reversal only for abuse of that discretion producing unfair trial)