State of Maine v. Dale F. Thistle

2024 ME 6
CourtSupreme Judicial Court of Maine
DecidedJanuary 25, 2024
DocketPen-22-225
StatusPublished
Cited by1 cases

This text of 2024 ME 6 (State of Maine v. Dale F. Thistle) 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. Dale F. Thistle, 2024 ME 6 (Me. 2024).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2024 ME 6 Docket: Pen-22-225 Argued: October 4, 2023 Decided: January 25, 2024

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

STATE OF MAINE

v.

DALE F. THISTLE

JABAR, J.

[¶1] Dale Thistle appeals from a judgment of conviction of theft by

misapplication of property (Class B), 17-A M.R.S. § 358(1)(A), (B)(1) (2023),

entered by the trial court (Penobscot County, Anderson, J.) after a jury trial.

Thistle argues that we must vacate his conviction because (1) the trial court

erred by not granting his motion for acquittal when the evidence established a

statute of limitations defense; (2) the trial court erred in its instructions to the

jury on the Maine Rules of Professional Conduct; (3) the State committed

prosecutorial error; and (4) the evidence was insufficient to convict him. We

affirm Thistle’s conviction. 2

I. BACKGROUND

[¶2] “When [the evidence is] viewed in the light most favorable to the

State, the jury could have rationally found the following facts.” State v. Fay,

2015 ME 160, ¶ 2, 130 A.3d 364. Dale Thistle was an attorney in Newport. As

part of his practice, he drafted a will for Gilman Friend in 2008. The will

nominated Donna Friend, Gilman’s ex-wife, as the estate’s personal

representative and devised a substantial portion of Gilman’s estate to her. The

will devised the remainder of the estate to Gilman’s four adult children.

[¶3] In December 2010, Gilman fell at his home. Emergency responders

treated Gilman for cuts and abrasions and then left Gilman at home with Donna.

Donna found Gilman dead the next morning. As personal representative of

Gilman’s estate, Donna hired Thistle to explore the possibility of a wrongful

death suit against the emergency responders’ employer. Thistle ultimately

negotiated a settlement on Donna’s behalf, and on July 2, 2012, he received a

check for $390,000 payable to “Donna Friend Personal Representative of the

[Estate of] Gilman Friend and Dale F. Thistle Esq.” Thistle deposited the check

into his IOLTA1 (client trust) account on July 13, 2012.

1 “IOLTA” stands for “interest on lawyer’s trust account.” M.R. Prof. Conduct 1.15(b)(4). A lawyer

must deposit and keep in an IOLTA account “[a]ll funds of any client . . . that are small in amount or held for a short period of time.” Id. Larger amounts of a client’s funds that will be held for a longer time must be kept in a separate account or in a pooled account in which the interest earned on the 3

[¶4] On August 2, 2012, Thistle consulted an attorney about whether the

proceeds of the wrongful death settlement should go to Donna or to Gilman’s

children.2 The attorney advised that, under both the will and 18-A M.R.S.

§ 2-804 (2009), the funds were statutorily required to go to Gilman’s children,

but Donna was entitled to recover her expenses in pursuing the action on behalf

of the estate. From the IOLTA account, Thistle then reimbursed Donna her

expenses and paid the consulting attorney. Accounting for these expenses, and

the approximately $96,300 Thistle was entitled to receive as an attorney fee for

the wrongful death claim, approximately $290,000 remained of the settlement

funds for Gilman’s children.

[¶5] At the end of July 2012, Thistle’s IOLTA account balance was

$379,703.20. By the end of November 2012, the balance was $280,703.28. And

by the end of January 2013, the account balance was $249,236.59. The balance

client’s funds can be accounted for and credited to the client. M.R. Prof. Conduct 1.15(b)(3). Interest earned on IOLTA accounts is paid to the Maine Justice Foundation “to provide services that maintain and enhance resources available for access to justice in Maine,” including “legal services, education, and assistance to low-income, elderly, or needy clients.” M. Bar R. 6(e)(3). 2 Thistle sought the attorney’s opinion on whether Donna, because she had been living with Gilman as a married partner at the time of his death despite their prior divorce, should receive part or all of the settlement as Gilman’s heir or whether the full settlement amount should pass to Gilman’s children. 4

never increased after January 2013. As of March 2014, the account balance was

only $21,958.62.

[¶6] Thistle made frequent withdrawals from the IOLTA account for

personal expenses, such as tax delinquency payments, payments to his son and

ex-wife, utility payments, home repair payments, and payments to himself.

Between July 2013 and March 2014, Thistle withdrew over $300,000 from the

IOLTA account, far more than the sum of Donna’s expenses, expenses of the

consulting attorney, and Thistle’s attorney fees in the settlement action.

[¶7] In May 2014, a receiver appointed to close Thistle’s practice

liquidated and closed the IOLTA account. When the receiver was appointed,

the account contained $15,445.92—not enough to pay Gilman’s children their

roughly $290,000 share of the settlement funds. Between Thistle’s receipt of

the settlement funds in July 2012 and the closure of his IOLTA account, Thistle

never paid Donna or Gilman’s children or notified the children that the

settlement award existed. Gilman’s children learned of the settlement award

only after Donna’s death in 2014. When they finally learned of the award, they

contacted the Board of Overseers of the Bar. 5

[¶8] On September 25, 2019, the State indicted Thistle for one count of

theft by misapplication of property (Class B), 17-A M.R.S. § 358(1)(A), (B)(1).3

When Thistle failed to appear in court on November 7, 2019, the court issued a

warrant for his arrest. Thistle, who was then living in Quebec, Canada, was

taken into custody by Canadian authorities and extradited. At his arraignment

on November 22, 2019, the court asked Thistle’s attorney how long Thistle had

been in Canada, to which Thistle himself responded, “Two and a half years.”

[¶9] The court held a three-day jury trial on June 15-17, 2022. The State

presented evidence that Thistle was aware that Gilman’s children were entitled

to the settlement funds; that Donna did not wish to distribute the settlement to

them despite that entitlement; that Thistle understood that professional and

ethical rules prohibited him from using client funds to pay his personal

expenses; and that Thistle made extensive withdrawals for personal expenses

from his IOLTA account after depositing the settlement funds. Thistle’s

attorney advanced two arguments in defense: first, that a head injury prevented

3 Title 17-A M.R.S. 4 358(1)(A) provides that a person is guilty of theft by misapplication of property if “[t]he person obtains property from anyone . . . upon agreement, or subject to a known legal obligation, to make a specified payment or other disposition to a 3rd person or to a fund administered by that person, whether from that property or its proceeds or from that person’s own property to be reserved in an equivalent or agreed amount, if that person intentionally or recklessly fails to make the required payment or disposition and deals with the property obtained or withheld as that person’s own.” Violation of section 358(1)(A) is a Class B crime if “[t]he value of the property is more than $10,000.” Id. § 358(1)(B)(1). 6

him from forming the requisite state of mind for theft by misapplication of

property, and second, that the State failed to produce sufficient evidence to

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Related

State of Maine v. Dale F. Thistle
2024 ME 6 (Supreme Judicial Court of Maine, 2024)

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2024 ME 6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-dale-f-thistle-me-2024.