State of Maine v. Cormier

CourtSuperior Court of Maine
DecidedJune 6, 2005
DocketCUMcr-04-1307
StatusUnpublished

This text of State of Maine v. Cormier (State of Maine v. Cormier) 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.

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State of Maine v. Cormier, (Me. Super. Ct. 2005).

Opinion

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Richard Cormier was indicted on June 10, 2004 and charged with two counts of manslaughter and separate counts of aggravated assault, aggravated operating under the influence, and reckless conduct with the use of a dangerous weapon as a result of a motor vehicle accident on May 11, 2003 in Raymond, which resulted in the death of Hazen Spearin and Blanche Spearin. Mr. Cormier filed a motion to suppress along with a detailed memorandum of law which was followed by a supplemental motion to suppress. The motions have been heard and fully briefed.

The accident involved a head on collision on Route 85 on the afternoon of Mother’s Day between the Cormier vehicle and the Spearin vehicle. Mr. Cormier was taken by ambulance to a hospital in Portland where a blood sample was taken from him pursuant to 29-A M.R.S.A. §2522(1) because a death had unfortunately occurred. That

statute states as follows:

If there is probable cause to believe that death has occurred or will occur as a result of an accident, an operator of a motor vehicle involved in the motor vehicle accident shall submit to a chemical test, as defined in section 2401, subsection 2401, subsection 3, to determine blood-alcohol level or drug concentration in the same manner as for OUI.

The blood sample was sent to the Maine Department of Human Services Health

and Environmental Testing Laboratory which prepared a report dated May 19, 2003

which indicated that a “Chemical Analysis of this sample showed: 0.08% ALCOHOL by WEIGHT.” The test results contained a preprinted notice that, “Any remaining evidence will be destroyed six (6) months from the analysis date unless claimed by the officer or a responsible official.”

Mr. Cormier was not initially charged by complaint with any crimes at all. After he was indicted, some thirteen months after the accident, his defense counsel requested access to the blood sample so that a separate test could be done to verify the accuracy of the 0.08% result. This was particularly important as there was no evidence at the scene of the accident that the defendant had been drinking.

Under Maine law, see 29-A M.R.S.A. §2411(1), a person is guilty of criminal operating under the influence if he either operates under the influence or operates a motor vehicle while having a blood-alcohol level of 0.08% or more. Since neither of the police officers who had contact with the defendant at the accident scene noticed any smell of alcohol or other evidence of alcohol consumption, the blood test was crucial to any prosecution for operating under the influence. As there was no evidence of excessive speed or any reason to impose criminal liability, other than liability based on alcohol consumption, the accuracy of a 0.08% test result was essential.

The defendant was informed, however, that a second test could not be done as the blood sample had been destroyed as part of a routine practice of disposing of old samples because of a shortage of storage space at the laboratory. As the chemist had no reason to know that this case involved deaths, as the State had not asked that the sample be set aside and saved, and as the defendant had not been charged, the sample was destroyed on January 23, 2004 more than eight months after the accident but before

indictment.

Mr. Cormier in his supplemental motion to suppress has requested that the results of the blood test be suppressed since the action of the State in destroying the sample prohibited him from having a second analysis done regarding the crucial blood test.

This argument fails. There are a number of useful precedents but two decisions of the Law Court and one of the Supreme Court of the United States are most helpful. In State v. Cyr, 588 A.2d 753, 5 (Me. 1991) a person convicted of arson claimed, “prejudice from the State’s failure to preserve exculpatory evidence.” In note 4 the Law Court stated,

“The State’s failure to preserve evidence does not violate a criminal

defendant's right to a fair trial unless (1) the evidence possesses an

exculpatory value that was apparent before the evidence was destroyed,

(2) the defendant would be unable to obtain evidence of comparable value

by other reasonably available means, and (3) the State acted in bad faith in

failing to preserve potentially useful evidence. State v. Lewis, 584 A.2d

622, 625 (Me. 1990).”

In State v. Anderson, 1999 ME 18 several defendants challenged the failure of the State to preserve a second breath sample for future reanalysis. The Law Court referred to California v. Trombetta, 467 U.S. 479 (1984) and determined that samples need not be preserved.

As stated by Justice Marshall in the Trombetta opinion at 481 “... the question presented is whether the Due Process Clause requires law enforcement agencies to preserve breath samples of suspected drunken drivers in order for the results of breath- analysis tests to be admissible in criminal prosecutions.” Justice Marshall’s opinion observed, at note 11, that California at that time automatically preserved blood samples but not breath samples. The methods of analysis that the Supreme Court and our Law

Court have utilized are more important that the type of sample tested or the routine

state procedures regarding preservation of samples.

In the Trombetta opinion the Supreme Court examined what it called “access-to evidence cases”, at 485-6, and discussed the “government’s duty to take affirmative steps to preserve evidence on behalf of criminal defendants”, at 486. The decision stressed the requirement that “Whatever duty the Constitution imposes on the States to preserve evidence, that duty must be limited to evidence that might be expected to play a significant role in the suspect’s defense.” See 488. The Court added that, “To meet this standard ... evidence must both possess an exculpatory value that was apparent before the evidence was destroyed, and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means.” See 489. The Court concluded that, since test results were generally reliable and since potential defects could be pointed out, no duty to preserve breath samples was required by the Due Process Clause of the Fourteenth Amendment. Trombetta at 489 and 491.

In this case the opportunity for a second analysis is more important given the 0.087% result and the lack of other evidence of impairment. The evidence did possess an exculpatory value, which should have been apparent before it was destroyed. The defendant would, however, have had the opportunity to present exculpatory evidence by other means, though perhaps not as conclusive as potentially demonstrating that the test result was inaccurate, including both a challenge to the test procedures and results and a vigorous presentation demonstrating that two trained officers and an ambulance attendant had failed to notice any sign, even the slightest, of alcohol consumption. Lastly, while the State should have requested that the blood not be destroyed, its careless inaction under these circumstances does not constitute acting in bad faith. The defendant’s supplemental motion to suppress is denied. Should this case ever proceed

to trial this Court would seriously consider allowing the defendant to comment to the

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Related

California v. Trombetta
467 U.S. 479 (Supreme Court, 1984)
Skinner v. Railway Labor Executives' Assn.
489 U.S. 602 (Supreme Court, 1989)
Ferguson v. City of Charleston
532 U.S. 67 (Supreme Court, 2001)
State v. Anderson
1999 ME 18 (Supreme Judicial Court of Maine, 1999)
State v. Lewis
584 A.2d 622 (Supreme Judicial Court of Maine, 1990)
State v. Cyr
588 A.2d 753 (Supreme Judicial Court of Maine, 1991)
State v. Roche
681 A.2d 472 (Supreme Judicial Court of Maine, 1996)

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State of Maine v. Cormier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-cormier-mesuperct-2005.