State v. Williams, 2012 ME 63

Williams, George, and Cassimy staged a false home invasion to murder George's husband.
George recruited Williams and Cassimy; motive was divorce and control of marital property.
The trio traveled from New York to Maine; they entered the home at night and used stockings as masks.
The victim was hog-tied, suffocated, and died; the culprits fled with the victim's car.
Cassimy pled guilty to conspiracy and agreed to cooperate; Williams and George were tried jointly with separate juries contemplated but denied.
Williams appeals on severance, cross-examination of a cooperating witness, prosecutorial vouching, and sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of severance or split juries	Williams argues severance required; joint trial prejudiced him	Joinder favored for efficiency; risk of prejudice controlled	Denial affirmed; no reversible prejudice found
Cross-examination of cooperating witness about prior arrests	Arrests admissible under 608(b) or 609; impeachment	Arrests too remote; not about truthfulness; prejudice	Court did not abuse discretion in excluding arrests
Prosecutor vouching for credibility of Cassimy	Prosecutor vouched for credibility via dates/times	No improper reliance; arguments within bounds	No Dale-like vouching; no error found
Sufficiency of the evidence	Concurrent evidence supports conspiracy and murder	Evidence inadequate to prove elements beyond reasonable doubt	Evidence sufficient to sustain convictions

Richardson v. Marsh, 481 U.S. 200 (1987) (non-testifying codefendant confession with curative instruction allowed)
Bruton v. United States, 391 U.S. 123 (1968) (redacted confessions may violate confrontation if effectively refer to defendant)
Quirion, 2000 ME 103 (Me. 2000) (co-conspirator statements admissible if in course and furtherance of conspiracy)
Lakin, 2006 ME 64 (Me. 2006) (joinder preferred; must show prejudice to severance)