207 A.3d 618
Me.2019Background
- In August 2016 Luc W. Tieman and his wife (the victim) returned to Maine; Tieman soon began an extramarital relationship and moved in with the other woman the day after the victim disappeared.
- The victim last communicated via Facebook Messenger on August 25; her body was found buried behind the Tieman family home on September 20, 2016, with a note signed by Tieman.
- Autopsy showed death by two gunshot wounds to the head and neck; .45 caliber fragments matched a .45 handgun seized from Tieman's residence.
- Tieman told police the victim had died of an overdose and that he buried her uninjured; he was arrested, indicted for murder, tried, convicted, and sentenced to 55 years.
- At trial the State admitted Facebook Messenger records of the victim’s messages (State’s Exhibit 74A); Tieman objected on authentication and hearsay grounds but later asked to admit the entire compiled Facebook record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authentication of Facebook Messenger records under M.R. Evid. 901 | State: witness who communicated with victim authenticated chat as true and accurate | Tieman: records not properly authenticated | Court: no clear error or abuse of discretion; Rule 901 satisfied by witness testimony (low bar) |
| Admissibility of victim's messages under hearsay exception M.R. Evid. 803(3) (then-existing state of mind) | State: victim's messages reflecting present emotions/plans admissible under 803(3) | Tieman: messages were hearsay and not within the state-of-mind exception (some refer to past events) | Court: admissible to the extent they reflect present state of mind; any erroneous admission of past-reflective statements was harmless given overwhelming other evidence |
| Sufficiency of the evidence for murder conviction | State: circumstantial and direct evidence (gunshot cause, matching .45, burial, motive, Tieman's statements) prove knowing or intentional murder beyond reasonable doubt | Tieman: evidence insufficient to prove murder | Court: viewing evidence in State’s favor, jury rationally could find every element proven beyond reasonable doubt; conviction affirmed |
Key Cases Cited
- State v. Perkins, 199 A.3d 1174 (Me. 2019) (standard for viewing evidence in light most favorable to State)
- State v. Berke, 992 A.2d 1290 (Me. 2010) (low-burden, flexible approach to electronic evidence authentication under Rule 901)
- State v. Churchill, 32 A.3d 1026 (Me. 2011) (electronic chat logs may be authenticated by participant testimony)
- State v. Cugliata, 372 A.2d 1019 (Me. 1977) (admission of state-of-mind hearsay requires circumstances indicating truthfulness)
- State v. Williams, 395 A.2d 1158 (Me. 1978) (distinguishing present state-of-mind statements from statements asserting past facts)
- State v. Hodgdon, 164 A.3d 959 (Me. 2017) (standard for reviewing sufficiency of evidence in criminal convictions)