State of Maine v. Craig A. Woodard

2025 ME 32
CourtSupreme Judicial Court of Maine
DecidedMarch 27, 2025
DocketHan-23-466
StatusPublished
Cited by2 cases

This text of 2025 ME 32 (State of Maine v. Craig A. Woodard) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Maine v. Craig A. Woodard, 2025 ME 32 (Me. 2025).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2025 ME 32 Docket: Han-23-466 Argued: October 8, 2024 Decided: March 27, 2025

Panel: STANFILL, C.J., and MEAD, HORTON, CONNORS, LAWRENCE, and DOUGLAS, JJ.

STATE OF MAINE

v.

CRAIG A. WOODARD

STANFILL, C.J.

[¶1] Craig A. Woodard appeals from a judgment of conviction and his

sentence for elevated aggravated assault, aggravated assault, and assault

entered by the trial court (Hancock County, Larson, J.) after a jury trial. At

sentencing, the court found that the State had pleaded and proved that the

offense of elevated aggravated assault was committed with the use of a firearm

and imposed the statutory mandatory minimum sentence of four years’

imprisonment, 17-A M.R.S. § 1604(3)(A) (2024). The court merged the offenses

and sentenced Woodard to twelve years’ imprisonment with all but five years

suspended and three years of probation. Woodard argues that the court erred

in failing to give jury instructions regarding defense of another. He also argues

that the court erred when it applied the mandatory minimum sentence for a 2

Class A offense committed with a firearm and considered Woodard’s age and

lack of remorse as aggravating factors. We disagree and affirm.

I. BACKGROUND

[¶2] Woodard and the victim “met” over Facebook. They engaged in

verbal altercations over Facebook Messenger, ultimately escalating into a

“scheduled fight” to occur at Woodard’s home. Woodard gave the victim his

address and invited him to a fistfight where the two could resolve their issues

“like gentlemen.” The victim accepted the invitation and traveled to Woodard’s

address with three friends.

[¶3] When the victim arrived at Woodard’s address, he saw Woodard

and his father standing outside. The victim initially remained on the public

road and yelled at Woodard, who was telling him to come further down the

driveway to fight. The victim stood with his hands out to the side, with his open

and empty hands visible. He proceeded a short distance down the way toward

Woodard, believing that if he fought on public rather than private property, he

was “pretty well safe.” When Woodard refused to come up the driveway

towards him, the victim announced that he had gone far enough and was

leaving because Woodard refused to come fight him. 3

[¶4] At that point, Woodard stepped behind a tree, grabbed a gun, and

fired a total of six shots in the victim’s direction. The victim turned and started

running back toward the public road. Woodard’s fourth shot struck the victim

just below his buttock.

[¶5] The victim thought he had been struck in the femoral artery and

believed he was going to die due to the amount of blood loss. He got in the car

with his friends, and they sped toward the hospital. A police officer met them

on the way and applied a tourniquet to the victim’s wound.

[¶6] Woodard was charged with elevated aggravated assault by criminal

complaint on May 8, 2020. He was then indicted on October 13, 2020, and

charged with elevated aggravated assault (Class A) (Count 1), 17-A M.R.S.

§ 208-B(1)(A) (2024); aggravated assault (Class B) (Count 2), 17-A M.R.S.

§ 208(1)(B) (2024); and assault (Class D) (Count 3), 17-A M.R.S. § 207(1)(A)

(2024). A jury trial was held on April 11, 2023, and the jury found Woodard

guilty on all three counts. Woodard moved for a judgment of acquittal on

April 25, 2023; the motion was denied after hearing on May 19, 2023. On

November 17, 2023, the court sentenced Woodard to twelve years’

imprisonment with all but five years suspended and three years of probation.1

1 The initial judgment and commitment, dated November 17, 2023, sentenced Woodard to 12 years on each count, with Counts 2 and 3 to run concurrently to Count 1. On December 12, 2023, 4

[¶7] Woodard timely filed an appeal from the judgment, see M.R.

App. P. 2B(b)(1), and sought leave to apply for sentence review, which the

Sentence Review Panel granted on January 31, 2024, see 15 M.R.S. § 2151

(2024), M.R. App. P. 20. Pursuant to M.R. App. P. 20(g)-(h), the two appeals

were consolidated, and we consider Woodard’s sentence appeal together with

his appeal from the judgment of conviction.

II. DISCUSSION

A. Jury Instructions Regarding Defense of a Third Person and Duty to Retreat

[¶8] At Woodard’s request, the court determined that the issue of

self-defense was generated by the evidence and instructed the jury accordingly.

See 17-A M.R.S. § 108(2)(A)(1) (2024). Woodard now argues that the evidence

also generated an issue of defense of third persons, specifically that because his

girlfriend and daughter were on the premises, the court erred in failing to so

instruct the jury. Additionally, he contends that there was no duty to retreat if

the jurors found that Woodard was acting to defend his family in their home.

the court issued an amended judgment and commitment, sentencing Woodard on Count 1 to twelve years with all but five years suspended and three years of probation, and merging Counts 2 and 3 into Count 1. 5

See id. § 108(2)(C)(3)(a). At trial, Woodard did not request these instructions

or object to the court’s failure to give them.

[¶9] Because the claimed errors in the instructions are admittedly

unpreserved, Woodard argues that we should review the court’s failure to give

these jury instructions for obvious error. See State v. Williams, 2020 ME 17,

¶ 24, 225 A.3d 751. On this record, however, it appears that the issue is not

only unpreserved but waived by Woodard. “If a defendant explicitly waives the

delivery of an instruction or makes a strategic or tactical decision not to request

it, we will decline to engage in appellate review, even for obvious error.” State

v. Nobles, 2018 ME 26, ¶ 34, 179 A.3d 910.

[¶10] Following an instructions conference and before the court

instructed the jury, defense counsel stated on the record that the proposed

instructions were acceptable. He also asked to explain on the record and in

Woodard’s presence why additional instructions were not requested.

Referring to defense of property under 17-A M.R.S. § 104 (2024), he stated:

Essentially, the same standards apply as in [section] 108. I’ve decided that it’s in his best interest not to make the case seem more complex than it is, and, so, I’m not raising a [section] 104 defense along with other items. That’s my judgment. It’s a strategy call. It could be reviewed by others who would disagree with my strategy. But, nonetheless, I have -- that’s my call. I’ve explained it to him, and I believe he accepts my judgment. 6

(Emphasis added.) Following up on counsel’s comments, the court explained

to Woodard that counsel was making a strategic choice and asked Woodard

three times on the record if he understood and was satisfied with defense

counsel’s strategy. Three times Woodard agreed that he understood and was

satisfied. Although defense counsel did not specify defense of others in his

explanation, it is clear that, with Woodard’s agreement, he strategically decided

to rely solely upon self-defense so as not to confuse the issues. And indeed,

self-defense is what was argued to the jury.

[¶11] We have noted that the trial court “is not required to instruct on

an affirmative defense that has been waived by the defendant.” State v. Ford,

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Cite This Page — Counsel Stack

Bluebook (online)
2025 ME 32, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-craig-a-woodard-me-2025.