State v. Matthews, 185 A.3d 46

Background

On Nov. 28, 2015, Matthews and the victim had separate interactions at two bars (Seasons and the Pour House) after the victim allegedly stared at Matthews’ group.
Matthews confronted and escorted the victim to a door at the Pour House; later he followed the victim across the street and, according to eyewitnesses, spun him around and repeatedly punched him.
Witnesses (a bouncer and a patron) observed Matthews strike the victim multiple times, including while the victim was on the ground and appeared unconscious.
Medical evidence showed multiple facial and orbital fractures, missing teeth, concussion, altered mental state, and testimony that the force used could have caused permanent or more serious injury.
Matthews claimed self-defense, testifying he was trained in mixed martial arts, that the victim swung at him, and that he struck to defend himself and to ensure the victim stayed down.
A jury convicted Matthews of aggravated assault (Class B) under 17-A M.R.S. § 208(1)(C); he was sentenced to four years with all but 18 months suspended and appealed, arguing insufficiency of evidence and that self-defense was not disproven beyond a reasonable doubt.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to show "extreme indifference" under § 208(1)(C)	State: injuries, manner of attack, and multiple strikes showed extreme indifference	Matthews did not dispute intent or injury; challenged sufficiency for extreme indifference	Court: Evidence (serious fractures, repeated post‑fall blows, physician testimony) was sufficient to show extreme indifference
Whether State disproved self‑defense	State: facts showed Matthews pursued and attacked, used excessive force, was initial aggressor or did not reasonably fear imminent harm	Matthews: claimed actual and reasonable belief of imminent unlawful force and necessity to use nondeadly force	Court: Jury could rationally find self‑defense disproven (pursuit, offensive reaction despite MMA training, multiple strikes after victim fell)
Whether force used was reasonable degree of nondeadly force	State: repeated punches to an apparently unconscious victim exceeded reasonable force	Matthews: argued strikes were defensive and to keep victim down	Court: Use of force was unreasonable—multiple punches after victim down and no signs of defense by victim supported verdict
Whether Matthews was initial aggressor or provoked the encounter	State: Matthews followed and confronted victim after victim left, showing initial aggression	Matthews: framed conduct as reaction to victim’s behavior and threat	Court: Jury could find Matthews was initial aggressor who pursued the victim, undermining self‑defense claim

Key Cases Cited

State v. Hall, 172 A.3d 467 (Me. 2017) (standard for reviewing sufficiency of evidence in light most favorable to the State)
State v. Fletcher, 122 A.3d 966 (Me. 2015) (self‑defense elements and excessiveness of force analysis)
State v. Dodd, 503 A.2d 1302 (Me. 1986) (interpreting "extreme indifference" as likelihood of death or serious bodily injury)
State v. Cunningham, 715 A.2d 156 (Me. 1998) (evidence supporting aggravated assault under extreme indifference criteria)
State v. Porter, 693 A.2d 743 (Me. 1997) (use of victim’s injuries and manner of attack to support extreme indifference)
State v. Ouellette, 37 A.3d 921 (Me. 2012) (enumeration of statutory self‑defense elements)
State v. Lagasse, 410 A.2d 537 (Me. 1980) (limitations on self‑defense when defendant continues to strike after victim is down)

Judgment affirmed.