State v. Saenz, 150 A.3d 331

Hilary Saenz died on Dec. 25, 2013, from a subdural hematoma and a lacerated liver after repeated physical assaults by her husband, Christopher Saenz, while their children were present.
Medical evidence: cause of death was blunt force trauma to head (subdural hematoma); >50 visible external bruises including many on the head and multiple internal bruises; some injuries were hours or days old.
Events: prolonged pattern of escalating assaults in days before death; on Dec. 25 Saenz searched the internet about being "knocked out," delayed effective emergency contact, and made inconsistent statements to responders about how Hilary was injured.
Defense: offered experts who testified a punch is an unlikely cause of a subdural hematoma and proposed a spontaneous seizure and fall as the more likely cause; evidence showed Hilary had no diagnosed seizure disorder and had denied prior seizures.
Trial/procedure: Saenz was tried without a jury, convicted of depraved indifference murder under 17-A M.R.S. § 201(1)(B), and sentenced to 47 years; he appealed arguing insufficient evidence on causation and depraved indifference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Causation — did Saenz’s conduct cause Hilary’s death?	State: blunt force trauma inflicted by Saenz caused the subdural hematoma (directly or by causing a fatal fall).	Saenz: experts said punches are unlikely to cause subdural hematoma; a spontaneous seizure and fall likely caused it.	Court: Sufficient evidence supported finding Saenz inflicted fatal blunt trauma; court could reject defense experts and infer causation.
Depraved indifference — was Saenz’s conduct sufficiently culpable?	State: repeated, severe assaults over days plus delay in seeking care manifested depraved indifference to human life.	Saenz: challenges sufficiency to show depraved indifference.	Court: Evidence supported that his conduct objectively created a very high risk of death and was unjustifiable; conviction affirmed.

State v. Erskine, 889 A.2d 312 (Me. 2006) (standard for reviewing sufficiency of the evidence)
State v. Hodsdon, 135 A.3d 816 (Me. 2016) (deference to fact-finder credibility determinations)
State v. Stinson, 751 A.2d 1011 (Me. 2000) (reasonable inferences may support factual findings despite conflicting direct evidence)
State v. Crocker, 435 A.2d 58 (Me. 1981) (definition and standard for depraved indifference murder)
State v. Witham, 876 A.2d 40 (Me. 2005) (application of depraved indifference concept)