State of Maine v. Lewis

CourtSuperior Court of Maine
DecidedMay 7, 2012
DocketKENcr-11-347
StatusUnpublished

This text of State of Maine v. Lewis (State of Maine v. Lewis) 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. Lewis, (Me. Super. Ct. 2012).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss CR-11-347 ~··fI l:zot2.. ·'

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STATE OF MAINE

v. SECOND ORDER ON DEFENDANT'S MOTION IN LIMINE PAULP. LEWIS

On May 3, 2012 the parties appeared before the Court pursuant to an order issued

February 1, 2012. That order provided the State with an opportunity to provide testimony

or evidence that the notice provisions contained in the Secretary of State's Certificate and

Notice of Suspension were created for a purpose other than criminal prosecution. The

State did have a witness from the Department of Motor Vehicles present in the

courtroom, but for reasons not clear to the Court, declined to call her.

The State at this hearing reiterated and/or clarified its claim that the effective date

of suspension is not an element of the offense of operating after suspension. The Court

disagrees with this contention. Mr. Lewis is charged by complaint with violation of29-A

MRSA 2412-A(l-A)(D). The elements of that offense very clearly require the State to

prove beyond a reasonable doubt that the person was operating a motor vehicle; that he

was under suspension; and the person had received notice in accordance with Maine law.

In this case, the State contends that the only elements it must establish are that he was

operating a motor vehicle and that he had notice of his suspension pursuant to Section

2482. The State seems to believe that whether or not he was under suspension is a

1 collateral matter that can only be challenged at a Secretary of State administrative hearing

and not at a criminal trial. 1

Section 2482 is entitled "Notice of suspension or revocation oflicense." The

Section contains four subparagraphs. The State insists, however, that the only paragraph

at issue in this case is subparagraph 1, and the State contends that it has been satisfied.

That position flies in the face of the plain wording of the Section as a whole. Subsection 2

says what must be contained within the notice, and paragraph B states that the "effective

date of the suspension" must be included in the notice. The State seems to argue that so

long as the effective date is referred to in the notice, that is all that is required. However,

that argument fails to take into account the definition of"effective date" provided in

subparagraph 4. By operation oflaw, the effective date is the date provided in the notice,

but that date cannot "be less than 10 days after the mailing of the notification of

suspension by the Secretary of State."

In State v. Maynard, 2012 ME 33, 34 the Law Court stated as follows: "At the

bench trial on the OAS charge, to prove that Maynard's right to operate motor vehicles

was suspended on September 2, 2010, and that notice of the suspension had been sent to

Maynard .... " (emphasis added). The Court believes that this is a recognition by the Court

(in addition to the plain wording of the statute) that the State must prove beyond a

reasonable doubt that the Defendant's operation occurred after the effective date of the

suspension. In Maynard, the effective date was not a live issue because the operation

occurred 23 days after the mailing.

1 In support of this position the State relies upon three cases, none of which supports the State's claim that it need not prove the effective date of the suspension. None ofthe cases cited (State v. Holmes, 2004 ME 155; State v. Piacitelli v. Quinn, 449 A.2d 1126 (Me. 1982); or State v. Higgins, 300 A.2d 159 (Me. 1975) address the issue of when a suspension goes into effect. They address what procedure should take place when it is someone challenges whether a suspension is justified under Maine law.

2 During oral argument on May 3, 2012, the State did concede that it cannot convict

someone who operates a motor vehicle after he or she has received notice of the

suspension, but whose operation occurs before the effective date. Nevertheless, the State

insists that because the notice was mailed sometime between August 19, 2008 and

sometime on September 2, 2008, its only obligation at trial is to obtain admission of the

Certificate and notice. The State suggests that these documents would not only constitute

prima facie evidence towards satisfying its burden, but proof beyond a reasonable doubt

that the Defendant was suspended at the time he operated his motor vehicle on September

12, 2008.

The Court finds that the effective date of Mr. Lewis' suspension must be proven

beyond a reasonable doubt. The effective date of his suspension cannot be "less than 10

days after the mailing of the notification of suspension" by the Secretary of State. In this

case, there is a range of possible mailing dates based on a prediction, made August 19,

2008, that the notice would be mailed by September 2, 2008. The proof problems

engendered by this prediction are obvious to the Court. These problems are made more

complicated by the statute's failure to give clear indication as to whether "not. .less than

10 days after the mailing of the notification of suspension" means that a fact-finder is to

start counting the 10 days from the moment the notice is mailed (sometime on the last

day of the range, September 2, 2008); or to count the next calendar day after the last date

in the range (September 3, 2008) as the first day of the ten days.

Given the obvious proof problems, the Court finds that the State would be unable

to carry its burden to prove the effective date of suspension beyond a reasonable doubt

without producing more evidence than the Certificate and notice of suspension. Because

3 the Court would avoid reaching a constitutional issue before trial when it is apparent that

the State cannot prove its case without calling witnesses to testify when the notice was

mailed within the range predicted, or at least when it was likely mailed given the

practices in place at the time of mailing, the Defendant will be given the right of 2 confrontation as he conceives it. As the Law Court held in Maynard, what is in a

particular certificate (or notice, as here) --even if admitted --may or may not be sufficient

to establish an element of the offense of operating after suspension beyond a reasonable.

The entry will be:

The Court declines to rule on the confrontation issue prior to trial. In order to meet its

burden of proof to establish that the Defendant's suspension was in effect at the time of

operation, the State given the unique facts presented in this case will have to rely upon

more evidence than the Secretary of State certificate and notice of suspension (State's

Exh. 1) as proffered.

DATE SUPERIOR COURT JUSTICE

2 The Court obviously does not know what that evidence might be. However, because the State might be able to prove through witnesses from the Dept. of Motor Vehicles that the notice was mailed soon after the date of the notice (August 19, 2008) there may be no need for the Court to interpret the "10 day" language in the statute. And, as noted above, the confrontation issue might be eliminated if the witnesses are called.

4 STATE OF MAINE SUPERIOR COURT vs KENNEBEC, ss. PAUL P LEWIS Docket No AUGSC-CR-2011-00347 32 WELLESLEY ESTS PORTLAND ME 04101 DOCKET RECORD

DOB: 04/18/1987 Attorney: ROBERT ANDREWS State's Attorney: TRACY DEVOLL ROBERT ANDREWS ESQ PO BOX 17621 PORTLAND ME 04112 APPOINTED 02/11/2011

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Related

Piacitelli v. Quinn
449 A.2d 1126 (Supreme Judicial Court of Maine, 1982)
State v. Maynard
2012 ME 33 (Supreme Judicial Court of Maine, 2012)
State v. Holmes
2004 ME 155 (Supreme Judicial Court of Maine, 2004)

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