State v. Seamon, 165 A.3d 342

Background

In June 2014 Detective Tori Tracy (plain clothes, unmarked cruiser, concealed recorder) interviewed Andrew Seamon at a friend’s house about allegations of sexual abuse of a child; Tracy did not give Miranda warnings or disclose the recording. The interview lasted about an hour and occurred at a location Seamon chose.
Seamon made various admissions and descriptions of potentially inappropriate conduct but did not admit to some of the specific sexual acts alleged. He later was indicted on two counts of gross sexual assault and one count of unlawful sexual contact; at trial the jury convicted on unlawful sexual contact, acquitted on one gross-assault count, and deadlocked on the other (later dismissed).
Seamon moved to suppress his statements, arguing they were involuntary and Miranda violations; the suppression court denied the motion, finding the interview noncustodial and Seamon’s statements voluntary.
At sentencing the court set a mid-range basic sentence (5–6 years) for Class B unlawful sexual contact, upward to a nine‑year maximum (with all but six years suspended) after weighing aggravating and mitigating factors (including multiple incidents described by the child).
The court informed Seamon he must register under Maine SORNA and supplied a SORNA 2013 form; the State later conceded Seamon should be notified under SORNA 1999 (lifetime registration) because his conviction occurred for a listed offense.

Issues

Issue	Seamon's Argument	State's Argument	Held
Whether the motion court erred by denying suppression of Seamon’s statements as involuntary	Statements were involuntary due to (a) Detective’s “excessively friendly” technique and (b) Seamon’s poor mental state (depression, recent psychiatric hospitalization)	Interview was noncustodial, noncoercive, at Seamon’s chosen location, short in duration, single plain‑clothed officer, no promises or threats; Seamon was coherent	Denial affirmed: totality of circumstances shows voluntariness; friendly demeanor and Seamon’s mental health did not render statements involuntary
Whether Miranda required suppression because no warnings were given	Miranda warnings should have been given because Seamon was effectively in coercive police questioning	Interview was noncustodial; Miranda not required	Miranda not triggered; suppression not required
Whether the court erred by considering multiple incidents (including those underlying acquitted or unresolved gross‑assault counts) in setting the basic sentence	Court improperly relied on alleged gross‑assault conduct and acquitted conduct to increase the basic sentence	Court may consider factually reliable, relevant information from trial testimony to determine basic sentence	Affirmed: court permissibly relied on the child’s trial testimony (factually reliable) to find multiple touching incidents for basic‑sentence calculation
Whether Seamon should have been ordered/ notified to register under SORNA 2013 rather than SORNA 1999	Trial court erred in directing SORNA 2013 registration	State concedes Seamon should be classified under SORNA 1999; the court only informed him about registration duty to be triggered at release	Remand/clarification: Seamon will be required to register under SORNA 1999 (lifetime) upon release; sentencing affirmed

Key Cases Cited

State v. Wiley, 61 A.3d 750 (Me. 2013) (officer’s explicit promise of leniency can render a confession involuntary)
State v. Hunt, 151 A.3d 911 (Me. 2016) (totality‑of‑circumstances voluntariness test and distinction between Fifth Amendment compulsion and fundamental‑fairness exclusion)
State v. Bryant, 97 A.3d 595 (Me. 2014) (standard of review for voluntariness; noncustodial interview factors)
State v. Mikulewicz, 462 A.2d 497 (Me. 1983) (confession voluntary if product of rational mind, not coercion, and fundamentally fair)
State v. Dumont, 507 A.2d 164 (Me. 1986) (trial testimony is factually reliable and may be considered at sentencing)