State of Maine v. Hutchins

CourtSuperior Court of Maine
DecidedDecember 16, 2009
DocketCUMcr-08-2614
StatusUnpublished

This text of State of Maine v. Hutchins (State of Maine v. Hutchins) 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
State of Maine v. Hutchins, (Me. Super. Ct. 2009).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss. CRIMINAL ACTION DOCKET NO. PORSC-08-2614 1..._ f I

STATE OF MAINE

v. ORDER

NICOLAS HUTCHINS

Hutchins is charged with a single count of Gross Sexual Assault (Class B), in

violation of 17-A M.R.S.A. § 253(2)(D). Hutchins filed a motion to dismiss alleging that

the destruction of audiotaped interviews of two key witnesses, including a nearly two

hour interview of the alleged, constitutes destruction of impeachment evidence, a due

process violation. According to the Law Court, a motion to dismiss "is not the

appropriate way to challenge the impermissible destruction of evidence." State v.

Bilynsky, 2007 ME 107, ~ 40, 932 A. 2d 1169, 1177. "[T]he suppression of that evidence

is the appropriate remedy." Jd. Thus, this court will treat the motion to dismiss as a

motion to suppress.

The state alleges that the assault occurred on August 24, 2008. Officer Twomey

interviewed Melody Michaud and Shawn Laverdiere, four days later on August 28, 2008.

The Laverdiere interview lasted twenty-five minutes. The Michaud interview lasted

nearly two hours. Both witnesses were present for both interviews. At the end of the

interviews, Twomey wrote the witness statements, read the statements back to the

witnesses and asked whether they had any corrections to their statements. The witnesses

1 then initialed their statements and Twomey forwarded the statements to his supervisor.

Twomey had no more involvement in the case.

The interviews were audiotaped. An auto recording runs all the time in the

witness room. The audiotape runs in a continual loop and an officer must request within

30 days preservation of a particular interview. The interview is preserved by extracting

the interview from the loop. If a timely request is not made, the interview is lost. Here,

Twomey did not request preservation of the interview tape, but he did mention it in his

report prepared the night of the interview, and he assumed that the detective-in-charge of

the case would request the tape if it had any value. The detective-in-charge, Maryann

Bailey, did not request preservation because she believed that officer who conducted the

interview would have made the request. 1 Unfortunately, neither officer requested that the

interviews be preserved. There is no evidence that either officer acted intentionally in

failing to preserve the interviews.

Hutchins argues that failing to preserve equals destruction in violation of his due

process rights, particularly here where the issue is whether the victim was incapable of

consenting where there were 7-1 0 minutes between intercourse with the witness and

victim and the defendant and the victim.

The Maine Law Court has adopted the two-part test developed by the United

States Supreme Court "to determine whether a defendant's right to due process is

violated by the failure to preserve evidence, (1) the evidence must possess an exculpatory

1 According to Bailey there is no standard operating policy regarding preservation of audio tapes but because of this case, she and other officers now e-mail officer who did the interview and advise them they must request preservation of the tape. There should be a standard operating procedure that preserves taped interviews conducted by the police.

2 value that was apparent before the evidence was destroyed; and (2) the evidence must be

of such a nature that the defendant would be unable to obtain comparable evidence by

other reasonably available means." State v. Bilynsky, 2007 ME at ~ 41 (citations and

quotations omitted). Applying the first step, the State concedes that the destruction of the

interviews deprived the defendant of impeachment evidence, and agrees that

impeachment evidence is exculpatory evidence. See Kyles v. Whitney, 514 U.S. 419,434

(1995). Applying the second step, there is no other way for the defendant to obtain

comparable evidence; there simply is no other comparable evidence once the interviews

were lost. Hutchins needs the interviews to impeach the testimony of the State's key

witnesses.

The next question then is whether the State acted in bad faith in failing to preserve

the evidence. State v. St. Louis, 2008 ME 101, ~ 7, 951 A. 2d 80, 81. Defendant argues

that both officers knew that the tape was potentially useful and both knew that it would

be lost if not preserved within 30 days, yet neither officer did anything to preserve the

tape. The State counters that the officers failed to preserve the evidence. The defendant

argues this is the same as destruction of the tape. Despite the State's serious oversight in

allowing the destruction of the interviews, the court cannot find that the state acted in bad

faith; there was no deliberate misbehavior. Accordingly, the motion to suppress is

denied.

The entry is:

Motion to Suppress Denied.

Date: December 16, 2009 ~. Wheeler, ~ •~ Justice <:

3 4 STATE OF MAINE SUPERIOR COURT VS CUMBERLAND, ss. NICOLAS C HUTCHINS Docket No PORSC-CR-2008-02614 150 SPRING ST #7 PORTLAND ME 04103 DOCKET RECORD

DOB: 05/14/1982 Attorney: TIMOTHY ZERILLO State's Attorney: STEPHANIE ANDERSON ZERILLO LAW OFFICES 103 EXCHANGE STREET PO BOX 17721 PORTLAND ME 04112 RETAINED 01/23/2009 Attorney: AMY ROBIDAS ZERILLO LAW OFFICES 103 EXCHANGE STREET PO BOX 17721 PORTLAND ME 04112 RETAINED 09/25/2009

Filing Document: CRIMINAL COMPLAINT Major Case Type: FELONY (CLASS A,B,C) Filing Date: 10/17/2008

Charge(s)

1 GROSS SEXUAL ASSAULT 08/24/2008 PORTLAND Seq 596 17-A 253 (2) (D) Class B Charged with INDICTMENT on Supplem BAILEY I POR

Docket Events:

10/20/2008 FILING DOCUMENT - CRIMINAL COMPLAINT FILED ON 10/17/2008

10/20/2008 WARRANT - ON COMP/INDICTMENT ISSUED ON 10/20/2008

CERTIFIED COPY TO WARRANT REPOSITORY ST 11/12/2008 Charge(s): 1 SUPPLEMENTAL FILING - INDICTMENT FILED ON 11/05/2008

01/21/2009 WARRANT - ON COMP/INDICTMENT EXECUTED ON 01/21/2009 BRENDA OLEARY , ASSISTANT CLERK-E 01/21/2009 Charge(s): 1 HEARING - ARRAIGNMENT SCHEDULED FOR 02/12/2009 @ 8:30 in Room No. 1

NOTICE TO PARTIES/COUNSEL 01/21/2009 BAIL BOND- $10,000.00 CASH BAIL BOND FILED ON 01/21/2009

Bail Receipt Type: CR Bail Amt: $10,000 Receipt Type: CK Date Bailed: 01/18/2009 Prvdr Name: NICOLAS C HUTCHINS Rtrn Name: 988 01/23/2009 WARRANT - ON COMP/INDICTMENT RETURNED q~,Ol/t0/2009

Page 1 of ,5 Printed on: 12/18/2009 NICOLAS C HUTCHINS PORSC-CR-2008-02614 DOCKET RECORD 01/23/2009 Party(s): NICOLAS C HUTCHINS ATTORNEY - RETAINED ENTERED ON 01/23/2009

Attorney: TIMOTHY ZERILLO 02/25/2009 Charge(s): 1 HEARING - ARRAIGNMENT HELD ON 02/12/2009 ROBERT E CROWLEY , JUSTICE READING WAIVED. DEFENDANT INFORMED OF CHARGES. COPY OF INDICTMENT/INFORMATION GIVEN TO DEFENDANT. 21 DAYS TO FILE MOTIONS 02/25/2009 BAIL BOND - CASH BAIL BOND COND RELEASE ISSUED ON 02/12/2009

Date Bailed: 01/18/2009 988 02/25/2009 Charge (s): 1 PLEA - NOT GUILTY ENTERED BY DEFENDANT ON 02/25/2009

02/25/2009 HEARING - DISPOSITIONAL CONFERENCE SCHEDULED FOR 04/15/2009 @ 10:30 in Room No. 7

02/25/2009 TRIAL - JURY TRIAL SCHEDULED FOR 05/04/2009@ 8:30 in Room No.

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Related

Kyles v. Whitley
514 U.S. 419 (Supreme Court, 1995)
State v. St. Louis
2008 ME 101 (Supreme Judicial Court of Maine, 2008)
State v. Bilynsky
2007 ME 107 (Supreme Judicial Court of Maine, 2007)

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