State v. Renfro, 157 A.3d 775

Police stopped Walter Renfro after observed erratic driving; officer observed indicia of intoxication and administered field sobriety tests.
At the station an Intoxilyzer breath test registered .17 g/210 L; Renfro was indicted for OUI and an equipment-related license violation.
An administrative hearing examiner later rescinded Renfro’s license suspension, finding the arresting officer failed to properly observe the 15-minute pre-test period before breath testing.
Before trial Renfro sought to admit the hearing examiner’s decision; the State moved to exclude it as irrelevant or prejudicial. The trial court found the decision relevant but excluded it under M.R. Evid. 403 as unfairly prejudicial and limiting impeachment.
The court nonetheless allowed impeachment: Renfro could cross-examine the officer about criticism of his observation practices and show a later video of the officer using improved procedures.
A jury convicted Renfro of OUI; he appealed, arguing the court abused its discretion in excluding the administrative decision and denied his mistrial motion challenging closing arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of administrative hearing decision	The hearing examiner’s decision showing improper pre-test observation is relevant and should be admitted to impeach the Intoxilyzer result	Admission would unfairly prejudice the jury and invite substitution of the examiner’s findings for the jury’s criminal factfinding	Exclusion affirmed under M.R. Evid. 403: probative value substantially outweighed by risk of unfair prejudice
Scope of impeachment evidence	Renfro needed the administrative decision to fully impeach the officer’s credibility and testing reliability	The court may limit impeachment to avoid substitution of administrative findings for jury factfinding	Court properly limited scope but allowed substantial impeachment (cross-exam and video of changed practices)
Effect of collateral administrative proceeding on criminal case	The administrative finding is probative of testing impropriety and admissible despite different forum	Administrative determinations are independent and based on different standards; admitting them risks juror overreliance	Court correctly noted statutory insulation of proceedings and excluded decision to prevent juror substitution of findings
Denial of mistrial for alleged burden-shifting in closing	Prosecutor’s closing shifted burden to Renfro, warranting mistrial	Any remarks did not prejudice defendant given accurate jury instructions	Denial of mistrial affirmed; no abuse of discretion or prejudice shown

State v. Kendall, 148 A.3d 1230 (Me. 2016) (standard for viewing evidence in favor of the State on appeal)
State v. Dean, 589 A.2d 929 (Me. 1991) (defining unfair prejudice under Rule 403)
State v. Roman, 622 A.2d 96 (Me. 1993) (trial court’s broad discretion in Rule 403 balancing)
State v. Bennett, 658 A.2d 1058 (Me. 1995) (limits on impeachment testimony lie within judicial discretion)
United States v. MacDonald, 688 F.2d 224 (4th Cir. 1982) (excluding administrative/military findings to protect jury factfinding)
State v. Huston, 825 N.W.2d 531 (Iowa 2013) (reversal where jury was given administrative substantiation that undermined jury’s role)

Judgment affirmed.