State of Maine v. Richard Peters

2024 ME 33
CourtSupreme Judicial Court of Maine
DecidedMay 7, 2024
DocketPen-23-252
StatusPublished
Cited by2 cases

This text of 2024 ME 33 (State of Maine v. Richard Peters) 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. Richard Peters, 2024 ME 33 (Me. 2024).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2024 ME 33 Docket: Pen-23-252 Argued: March 5, 2024 Decided: May 7, 2024

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

STATE OF MAINE

v.

RICHARD PETERS

MEAD, J.

[¶1] Richard Peters appeals from a judgment of conviction for hunting a

deer after having killed one (Class D), 12 M.R.S. § 11501(2) (2024), and

unlawful possession of wild animals (Class E), 12 M.R.S. § 10658(1) (2024),

entered by the trial court (Penobscot County, Lucy, J.) following a jury trial.

Peters challenges the court’s denial of his motions for a mistrial, the sufficiency

of the State’s bill of particulars, and the jury instructions. He further contends

that double jeopardy protections barred his conviction on the charge of

unlawful possession of wild animals. We disagree with his contentions and

affirm the judgment.

[¶2] The court initially stayed Peters’s sentence to require him to report

to the Androscoggin County Sheriff’s alternative sentencing program. Peters 2

contends that after he took an appeal, the court construed M.R.U. Crim. P. 38(d)

too strictly when it amended the stay to require him to surrender to the

Penobscot County Sheriff to serve his sentence. We agree with Peters that the

court retained the authority to order the original stay and we remand for the

court to consider whether to reinstate it.

I. BACKGROUND

A. Facts

[¶3] “Viewing the evidence in the light most favorable to the jury’s

verdict, the trial record supports the following facts.” State v. Healey,

2024 ME 4, ¶ 2, 307 A.3d 1082 (quotation marks omitted).

[¶4] On November 16, 2019, during the open hunting season for deer,

Game Warden William Shuman went to Peters’s residence after receiving a call

from a game registration station in Etna. The registration agent told Shuman

that on November 13, Peters had registered a doe that he killed, and on

November 15, Peters returned to the station with Ruth Smith, who was there to

register a buck that she had purportedly killed and who gave the same phone

number as Peters. The agent became suspicious when Peters did all of the

talking concerning the buck.

[¶5] Accompanied by Game Warden Josh Beal, Shuman went to Peters’s 3

home to investigate; eventually a third warden came with an

evidence-detection dog. When he arrived, Shuman saw Peters and another man

hanging a large buck from the garage. Peters acknowledged killing a doe on his

property on November 13 using a .300 caliber rifle. Concerning the buck,

Peters told Shuman that Smith, who held an apprentice hunting license,1 shot it

with a .30-06 rifle while they were together in the woods on the property.

Asked to explain how that had happened, Peters said that he had “paunched”

the deer by shooting it in the stomach, requiring him to “chase the deer around”

and kill it with a neck shot. When Shuman pointed out that Peters had just

acknowledged shooting the buck in the stomach and the neck using the word

“I” to identify who had performed those acts, Peters became irritated and said

that the warden was putting words in his mouth, and that when he used “I” he

meant “we or them.”

[¶6] The wardens conducted an investigation that included examining

various boot tracks, drag marks, ATV tracks, deer tracks, blood, and a gut pile

along a snowmobile trail on the property, and they discovered two bait sites—

one an apple pile and the other a foam fake tree stump containing bait, which

1 Shuman explained that an apprentice hunter requires a qualified supervisor. See 12 M.R.S. § 11108-B(1) (2020) (subsequently amended by P.L. 2019, ch. 639, §§ 2-5 (effective June 16, 2020) (codified at 12 M.R.S. § 11108-B(1) (2024))). 4

was located in front of a tree that had a blood spatter and what appeared to be

a bullet strike.

[¶7] The wardens obtained and executed a search warrant for Peters’s

residence. Among the items seized were a .300 caliber rifle and a .30-06 rifle.

B. Procedure

[¶8] Peters was charged by criminal complaint with, in Count 1: hunting

a deer after having killed one (Class D), 12 M.R.S. § 11501(2);

Count 2: exceeding the bag limit on deer (Class D), 12 M.R.S. § 11501(1) (2024);

Count 3: unlawful possession of wild animals (Class E), 12 M.R.S. § 10658(1);

and Count 4: illegally baiting deer (Class E),2 12 M.R.S. § 11452(1)(B) (2020).

[¶9] The court held a jury trial on May 16 and 17, 2023, at which five

wardens testified. After the State rested its case-in-chief, the court granted

Peters’s motion for a judgment of acquittal as to Count 4, which alleged that

Peters had hunted from an observation stand or blind overlooking bait. The

jury returned verdicts of guilty on Counts 1 and 3 and not guilty on Count 2.

[¶10] At the sentencing hearing, the court entered judgment and

imposed the minimum mandatory penalties: three days’ incarceration and a

2 At the time of the alleged offense, illegally baiting deer was a Class E crime; the statute has since

been amended to make this a civil offense. P.L. 2019, ch. 630, § 3 (effective June 16, 2020) (codified at 12 M.R.S. § 11452(2) (2024)). 5

$1,000 fine on Count 1 and a $500 fine on Count 3. 12 M.R.S. §§ 10658(2),

11501(3) (2024). By agreement, the judgment specified that the jail term was

stayed so that Peters could serve the sentence through the Androscoggin

County alternative sentencing program. The court did not act on the State’s oral

request to forfeit the .30-06 rifle, determining that the State had cited no

persuasive statutory basis for it to do so.3

[¶11] Peters timely appealed and moved for a stay of execution pending

appeal. M.R. App. P. 2B(b)(1). The court granted the motion but stated that

Peters “shall be aware that [M.R.U. Crim. P.] Rule 38(d) applies as to his jail

sentence if his appeal is unsuccessful. That rule does not allow for

accommodating alternative sentencing program delays.” In accordance with its

interpretation of Rule 38(d), the court amended the judgment by striking the

original stay permitting the alternative sentencing program in Androscoggin

County and substituting an ordinary stay pending appeal, following which

Peters would be required to surrender to the Penobscot County Sheriff to serve

his three-day sentence.

3 On appeal, Peters asks us to order that the firearms seized by wardens be returned to him. We

conclude that this issue is not ripe for our decision given that there has been no libel proceeding against the firearms in the trial court pursuant to 12 M.R.S. §§ 10502-10503 (2024), nor has Peters moved for return of the property pursuant to M.R.U. Crim. P. 41(j). Accordingly, we do not discuss the issue further. See State v. Carrillo, 2018 ME 84, ¶ 4, 187 A.3d 621. 6

II. DISCUSSION

A. Motions for Mistrial

[¶12] In June 2022, almost a year before trial, Peters moved for an order

requiring the State to produce a report concerning any expert that it intended

to call; the court granted the motion. The State did not produce any such report.

The day before trial, Peters moved in limine for a pretrial ruling on the

admissibility of evidence concerning “[a]ny testimony regarding a matching of

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Bluebook (online)
2024 ME 33, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-maine-v-richard-peters-me-2024.