Craig v. State of Maine

CourtSuperior Court of Maine
DecidedOctober 27, 2021
DocketAROcr-18-40877
StatusUnpublished

This text of Craig v. State of Maine (Craig v. State of Maine) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craig v. State of Maine, (Me. Super. Ct. 2021).

Opinion

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STATE OF MAINE SUPERIOR COURT AROOSTOOK, ss DOCKET NO. CR-18-40877

ROBERT CRAIG ) Petitioner ) ) ) ) vs ) DECISION ) ) ) STATE OF MAINE ) Respondent )

INTRODUCTION

Pending before the court is Robert Craig's (hereafter "Craig") Petition for Post­

Conviction Review. Hearing on the petition was held on October 18, 2021. Testimony was

received from the Petitioner Robert Craig (hereafter "Craig") and Attorney Stephen Smith. Also

admitted into evidence is Petitioner's Ex. 1 (Pet. Ex. 1), which is titled "Robert Craig- Outline of

Claims". This was offered to also serve as Craig's amended petition. And also admitted into

evidence were three (3) letters from Attorney Smith to Craig, to wit:

State Ex. 1- letter dated April 18, 2017;

State Ex. 2- letter dated May 19, 2017

State Ex. 3- letter dated June 7, 2017

With agreement of the parties, the record also includes, and the court has considered, the

docket sheets and file contents ofthe underlying criminal charge and the transcript of trial

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proceedings. (hereafter references to trial transcript are by volume and page number (T. V._,

p._)).

ISSUES IDENTIFIED

By an indictment dated September 9, 2016, Craig was charged with having committed on

or about July 21, 2016 the intentional and knowing murder of Leo Coniveau (hereafter

"Corriveau"). Trial was held in July, 2017. Craig raised self-defense during the trial. The jury

was instructed on the elements of self-defense and the lesser included offense of manslaught~r.

The jury returned a verdict of guilty to murder, and Craig was sentenced to 33 years. At

sentencing, counsel told the court Craig had authorized him to tell the court he would not be

filing an appeal. (T. Sentencing Volume, p. 13).

In his initial handwritten petition dated August 9, 2018, 2018, Craig alleges ineffective

assistance of counsel in that counsel failed to present mitigating evidence, impeach witnesses,

other various deficiencies, and also failed to perfect an appeal. At hearing, and as identified in

Craig's Outline of Claims, Craig focused his claims to counsel's failure to introduce evidence of

Coniveau's history for violence and other bad acts that would have been relevant to Craig's state

of mind. (See Pet. Ex. 1). The claims are numbered one through eleven in the Outline of Claims,

and will be addressed by that numbering in this decision.

STANDARD OF REVIEW

Claims of ineffective assistance of counsel raised on post~conviction review are governed

by the two -part test outlined in Strickland v. Washington, 466 U.S. 668 (1984). Applying that

test, a petitioner bears the burden, at the post~onviction trial, ofproving the following: (1)

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counsel's representation fell below an objective standard ofreasonableness, and (2) the deficient

representation resulted in prejudice. Philbrook v. State, 2017 ME 162, 16. The second prong of

the test is also described as whether e1Tors of counsel actually had an adverse effect on the

defense. Fahnley v. State, 2018 ME 92,117; Hodgdon v. State, 2021 ME 22,111.

As to the first prong of the test, counsel's representation falls below the objective

standard of reasonableness if it falls below what might be expected from an ordinary fallible

attomey. Philbrook, 17. Judicial inquiry into the effectiveness is highly deferential, and the post­

conviction court must make every effort to eliminate the distorting effects of hindsight. Id

Judicial inquiry into the effectiveness of representation is highly deferential, and the court must

indulge a strong presumption that counsel's conduct falls within the wide range of reasonable

conduct. Watson v. State, 2020 ME 51, 120, At the same time however, a determination that

defense counsel's choices amount to trial strategy does not automatically insulate them from

review. Id

In Roberts v. State ofMaine, 2014 ME 125,123,103 A.3d 1031,1039, the Law Court

indicated that in order to prove that counsel's performance was constitutionally deficient,

"a defendant must show that counsel's representation fell below an objective standard of reasonableness. The question is whether the counsel's performance fell within the wide range of reasonable professional assistance that a competent criminal defense counsel could provide under prevailing professional norms. The Strickland test compels us to reconstruct the circumstances of counsel's challenged conduct and to evaluate the conduct from counsel's perspective at the time." (Intemal citations and punctuation omitted.)

As to the second prong, whether prejudice is established, a petitioner must prove that

there is a reasonable probability that, but for counsel's unprofessional errors, the result of the

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proceeding would have been different, meaning that the ineffective assistance of counsel rose to

the level of compromising the reliability of the conviction and undermining confidence in it.

Philbrook,~ 8; citing Theriaultv. State, 2015 ME 137, 1~ 19, 25. A conviction may be unreliable

and not worthy of confidence, thus satisfying the reasonable probability test, even without proof

that a different outcome was "more likely than not'', as the now superseded "outcome

determinative" test would require. Id The "reasonable probability" test is different from an

"outcome-determinative" standard, which is the quantitative inquiry that would require proof

"that counsel's deficient conduct more likely than not altered the outcome h1 the case." Theriault,

~20. Rather, the court's analysis must be qualitative in nature-that is to determine whether the

petitioner has demonstrated that trial counsel's perfonnance undermines confidence in the

outcome of the case and renders that outcome unreliable, Theriault, 119. " .. the result of a

proceeding can be rendered unreJiable, and hence the proceeding itself unfair, even if the errors

of counsel cannot be shown by a preponderance of the evidence to have determined the

outcome." Theriault, 120, citing Strickland, 466 U.S., at 694.

More specific to this case, Craig is asse1·ting that his counsel was ineffective to not

introduce more evidence of prior events or prior conduct by the victim Leo Corriveau that Craig

was aware of by the time of the incident. Craig raised self-defense. While evidence of a victim's

character or bad acts is generally not admissible to prove that a person acted in conformity

therewith, when an accused raises self-defense, a defendant's knowledge of prior acts of

violence, whether witnessed by or recounted to the defendant, are not excluded by M.R.Evid

404, as the evidence serves to establish that the defendant's mental judgments and physical

responses during the encounter were reasonable. State v. Stanley, 2000 ME 22, 18,9; State v.

Laferriere, 2008 ME 67, 14,

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DISCUSSION

Craig's primary assertion of ineffective counsel, as listed in his Outline of Claims, is

counsel's failure to offer more evidence of Corriveau's prior acts of violence and bad character.

Before addressing Craig's list of deficiencies as set forth in his Outline, it is flrst necessary to

review some of the background of their relationship, and the event that caused Coniveau's death.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Daniel P. Roberts v. State of Maine
2014 ME 125 (Supreme Judicial Court of Maine, 2014)
Mark J. Theriault v. State of Maine
2015 ME 137 (Supreme Judicial Court of Maine, 2015)
John Fahnley v. State of Maine
2018 ME 92 (Supreme Judicial Court of Maine, 2018)
Richard Watson v. State of Maine
2020 ME 51 (Supreme Judicial Court of Maine, 2020)
Benjamin H. Hodgdon II v. State of Maine
2021 ME 22 (Supreme Judicial Court of Maine, 2021)
State v. Stanley
2000 ME 22 (Supreme Judicial Court of Maine, 2000)
State v. Laferriere
2008 ME 67 (Supreme Judicial Court of Maine, 2008)
Philbrook v. State
2017 ME 162 (Supreme Judicial Court of Maine, 2017)

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Craig v. State of Maine, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-v-state-of-maine-mesuperct-2021.